Withholding tax and debt capital, including the planned revision of the Withholding Tax Act
In terms of withholding tax, we focus on withholding tax on the income from equity securities. In particular, pecuniary benefits occupy us and often lead to emotionally profound experiences and contacts with withholding tax. Similarly, we constantly deal with the question of the refund of withholding tax owed, including the issue of "How can I repatriate profit reserves subject to withholding tax abroad?
Refund of withholding tax in international relations
The refund of withholding tax on dividends from Swiss companies by foreign shareholders can only be made on the basis of a double taxation agreement between Switzerland and the country of residence of the claimant. In order to claim relief from withholding tax under the applicable double taxation treaty, the residence of the claimant must be confirmed by the foreign tax authorities.
Transfer of the registered office to Switzerland - A case for the old reserve practice?
The problem of old reserves has become an integral part of daily tax consulting practice in Switzerland. The corresponding problem will be examined in this article on the basis of a transfer of the registered office of a foreign company to Switzerland. Here, too, the Federal Tax Administration (FTA) initially assumed that the "old reserves" brought into Switzerland were subject to Swiss abuse practice without restriction.
Procedural law: The withholding tax as a self-declaration tax
The withholding tax is a self-declaration tax: The taxpayer is responsible for declaring the withholding tax and fulfilling his tax liability. In contrast to the mixed assessment procedure, the procedure is not characterised by the cooperation of tax authorities and taxpayers. The responsibility for the payment of the withholding tax, including the determination of the assessment basis, lies solely with the taxpayer.
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)
Adjustment of the private share in the car costs in the leaflets N1/2007 and NL1/2007
On 22 March 2022, the FTA amended the information sheets N1/2007 and NL1/2007, as Art. 5a para. 2 of the Federal Ordinance on Professional Costs came into force on 01 January 2022, which now provides for a higher flat-rate travel cost deduction of 0.9% of the purchase price of the vehicle as monthly income.
Federal Council opens consultation on implementation of OECD/G20 minimum taxation
On 11 March 2022, the Federal Council decided that the OECD/G20 project on the taxation of the digital economy in Switzerland should be implemented in stages with a constitutional norm and transitional provisions. The corresponding consultation will last until 20 April 2022.
Circular No. 5a Restructuring
The new circular no. 5a on tax-neutral reorganisations was published on 1 February 2022. The following key adjustments were made in the circular:
Tax-approved interest rates 2022 for advances or loans in Swiss francs and in foreign currencies
On 27 January 2022, the FTA updated the circular on the tax-recognised interest rates in Swiss francs, and on 28 January 2022, the circular on the recognised interest rates 2022 in foreign currencies.
OECD Minimum Tax: Implementation with a Constitutional Amendment
On 13 January 2022, the Federal Council announced that it would like to implement the agreed minimum tax for certain companies with a constitutional amendment. A temporary ordinance is to ensure that this can come into force on 01 January 2024. Subsequently, the law will be enacted through the ordinary legislative process.
FTA announces imputed interest rate on security equity 2022
On 6 January 2022, the FTA announced that the imputed interest rate on the security capital pursuant to Art. 25abis para. 4 sentence 1 StHG, which corresponds to the yield on 10-year federal bonds on the last trading day of the calendar year preceding the start of the tax period, will continue to be 0% for the 2022 tax year due to the negative yield.
Dossier on tax information "Cryptocurrency" published
The FTA has published a new article "Cryptocurrency" for the tax information dossier.
FTA publishes updated working paper on cryptocurrencies and ICOs/ITOs
The FTA has updated its working paper on cryptocurrencies and initial coin/token offerings (ICOs/ITOs) as a subject of wealth, income and profit tax, withholding tax and stamp duties. It reflects the state of practice as of the end of 2020.
.jpg)
Carve-outs and real estate transactions
Workshop on "Carve-outs and Real Estate Transactions" by Maxim Dolder and Gianfranco Gambaro on the occasion of the ISIS seminar "Current Tax Topics in M&A Transactions" on March 21, 2024.
Social security law issues in transactions
Workshop on "Social security law issues in transactions" by René Aeschlimann and Martin Leu on the occasion of the ISIS seminar "Current tax issues in M&A transactions" on March 21, 2024.
Pillar 2 for M&A transactions and mergers
Workshop on "Pillar 2 in M&A transactions and mergers" by Thomas Hug and Flurin Poltera on the occasion of the ISIS seminar "Current tax topics in M&A transactions" on 21 March 2024.
ISIS) seminar folder "Current tax topics in M&A transactions" (2024)
All documents from the ISIS) seminar "Current tax topics in M&A transactions" from March 21, 2024 under the direction of Susanne Schreiber in one PDF document. Case studies, detailed solution notes and slides: Here you will find all documents of the individual workshops according to the following content description.
