Automatic exchange of information and (unpunished) voluntary declarations
Since 1 January 2010, taxpayers in Switzerland have been able to go unpunished when they report tax evasion for the first time. Since then, tax transparency has increased internationally. Switzerland is pursuing the approach of implementing the international minimum standards. This now also includes the automatic exchange of information. On the way to a transparent taxpayer, the question arises as to whether the possibility still exists or should exist for taxpayers to disclose previously untaxed assets without having to expect a fine.
"Mother-daughter" arrangement between Italy and Switzerland
Opinion No. 537 of 6 August 2021 of the Italian tax authorities, described in this article, is a further sign of the "normalisation" of income tax relations between Italy and Switzerland.
Implementation of the tax reform and AHV financing (STAF) in the canton of Solothurn and first practical experiences
With the adoption of the STAF by the Swiss electorate on 19 May 2019, the cantonal tax privileges were abolished in all cantons as of 1 January 2020 and replaced by instruments that are internationally accepted. While the Solothurn electorate approved the STAF at federal level with 58.6% of the vote, it simultaneously rejected the first cantonal proposal to implement the STAF, which would have provided for a significant reduction in the profit tax rate, with 51.4% of the vote. In the second proposal, which was accepted by the electorate, it was possible to agree on a less extensive, but still substantial, reduction of the profit tax rate. For the city of Solothurn, for example, the effective profit tax rate for legal entities will be 15.29% from 2022 (previously: 21.23%). In addition to this reduction in the profit tax rate and the legislative changes prescribed by the Federal Act on the Harmonisation of Direct Taxes of the Cantons and Municipalities (StHG), individual provisions of the Tax Act were adapted to the new accounting law with the implementation of the STAF in the Canton of Solothurn and accompanying measures were adopted in the area of natural persons.
Compensation paid by Swiss companies to foreign directors
This video provides information on the possible tax and social security implications of a board of directors resident in an EU country in the case of a Swiss company limited by shares if the board of directors is also self-employed in its country of residence.
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OECD publishes report on transfer prices in financial transactions
On 11 February 2020, the Organisation for Economic Cooperation and Development (OECD) published a report containing guidelines on the transfer pricing aspects of financial transactions.
Circular letter 34 of the Swiss Tax Conference (SSK)
On 15 January 2020, the Swiss Tax Conference (SSK) published Circular Letter 34 on the "Intercantonal tax separation of companies claiming the deductions provided for in the STAF" for the additional deductions newly introduced for state and municipal taxes - but not for direct federal taxes - following the entry into force (1 January 2020) of the Federal Law on Tax Reform and OASI Financing (STAF) of 28 September 2018.
Tax-deductible interest rates 2020 for advances or loans in Swiss francs and foreign currencies
The granting of interest-free or insufficiently interest-bearing advances or loans to participants or third parties related to them constitutes a payment in kind. This shall also apply to translated interest which is paid on the basis of obligations to participants or third parties close to them.
FTA publishes Circular Letters 22a and 23a concerning the partial taxation of income from investments held as private and business assets
On 31 January 2020, the Federal Tax Administration (FTA) published Circular Letters No. 22a "Partial Taxation of Income from Participations as Part of Private Assets and Restriction of Debt Interest Deduction" and No. 23a "Partial Taxation of Income from Participations as Part of Business Assets and Participations Declared as Business Assets".
OECD publishes statement on taxation of multinational companies
On 31 January 2020, the Organisation for Economic Cooperation and Development (OECD) published a statement on taxation of multinational (digital) companies, according to which an agreement should be in place by the end of 2020 (see also taxlawblog contributions of 12 October 2019 and 9 November 2019).
SIF updates list of DTAs with abuse provisions
On 17 January 2020, the Bilateral Tax Issues and Double Taxation Division of the State Secretariat for International Financial Matters (SIF) updated the list of agreements with abuse provisions.
Canton ZH: Changes to the flat-rate tax credit
The ordinance on the implementation of the flat-rate tax credit was adapted to the new requirements of federal law as of 1 January 2020. On the same date, the Ordinance on cantonal tariffs for calculating the maximum amount up to which a flat-rate tax credit can be granted to natural persons was repealed.
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Employee vs. entrepreneurial participation in stock corporation law, accounting and tax practice; outlook on the corporate tax reform
Workshop on the occasion of the ISIS) seminar on 4/5 June 2018 on "Current problems and perspectives of corporate tax law".
Current problems of intercantonal and international corporate tax law (2018)
Workshop on the occasion of the ISIS) seminar on June 4/5, 2018 on the topic "Current problems and perspectives of corporate tax law".
