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.
.jpg)
.jpg)
Federal Council enacts Federal Act on the Taxation of Telework as of 1.1.2025.
At its meeting on October 16, 2024, the Federal Council decided to bring the Federal Act on the Taxation of Teleworking into force on January 1, 2025.
New circular no. 6a: Hidden equity capital
On October 10, 2024, the FTA published the updated circular no. 6a regarding "Hidden equity".
Taxes in the cost-plus method - FTA publishes statement on the ruling of the Federal Supreme Court 9C_37/2023
In its ruling 9C_37/2023 of June 11, 2024 (see our article), the Federal Supreme Court addressed, among other things, the question of whether or not the tax expense should be taken into account in the cost base when applying the cost-plus method in the context of Art. 58 para. 3 DBG.
FTA - Notification withholding tax: Declaration of reserves from capital contributions
On September 18, 2024, the FTA clarified the administrative practice in accordance with item 9 of circular no. 29c on the capital contribution principle dated December 23, 2023 regarding the declaration of reserves from capital contributions.
International supplementary tax IIR to come into force in 2025
At its meeting on September 4, 2024, the Federal Council decided to bring the Income Inclusion Rule (IIR) into force on January 1, 2025. In addition to the QDMTT, which was already introduced on January 1, 2024, this rule is intended to ensure that tax revenue remains in Switzerland.
Transitional solution for the too-big-to-fail instruments for withholding tax
At its meeting on August 21, 2024, the Federal Council approved a temporary extension of the special regulations for interest from TBTF instruments until December 31, 2031. Without an additional extension, interest on TBTF instruments issued after December 31, 2026 would be subject to withholding tax.
.jpg)
Transactions et restructurations - Partie 2
Atelier de Arthur Magnin à l'occasion du séminaire ISIS) du 7 novembre 2023 intitulé "Actualités en matière d'impôt anticipé / Droits de timbre"
Dossier de séminaire ISIS) "Actualités en matière d'impôt anticipé / Droits de timbre" (2023)
Etudes de cas, solutions détaillées et transparents : vous trouverez ici tous les documents des différents ateliers selon la description du contenu ci-dessous du séminaire ISIS) "Actualités en matière d'impôt anticipé / Droits de timbre" du 7 novembre 2023 sous la direction de Laila Rochat.
