Place of actual administration in the age of digitalisation & home office
Since the concept of the place of actual administration was incorporated into the law in 1951, digitisation has progressed in great strides. The author explores the question of the extent to which, in the age of home offices and video conferencing via the internet, criteria such as office space, lack of staff, lack of telephone accessibility and address redirection are still contemporary and whether the place of actual administration can still be determined geographically at all in the face of increasing mobility.
STAF transitional rules from an international perspective
Developments in international tax law have increased rapidly in recent years. The BEPS project to combat base erosion and profit shifting (BEPS), initiated by the OECD and the G20 countries, was the main trigger for this unprecedented dynamic. With a comprehensive package of measures consisting of 15 action points, the aim is to take international action against harmful tax competition and aggressive tax structuring and thus prevent undesirable profit reduction and profit shifting.
Relocation of businesses, functions and assets for profit tax purposes under VAT law
Within the framework of the STAF, a legal basis for the recording of cross-border inbound and outbound relocations of operations, functions and assets has been created at the federal, cantonal and municipal level. The question arises as to how such relocations should be treated for VAT purposes. The treatment is particularly relevant for inbound relocations in industries with a reduced input tax rate. As an outflow of the "dual entity" approach, relocations within the same legal entity between headquarters and permanent establishment are of interest.
Editorial for the special issue "Implementation of the STAF
At zsis we are pleased to be able to provide an overview of the implementation of the corporate tax reform in the individual cantons. The authors not only provide information on the reduction of the profit tax rate, but also highlight the change from tax privileges to ordinary corporate taxation. They also report on the other cantonal particularities.
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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FDF publishes first report on cantonal measures in connection with the implementation of the OECD minimum tax
On August 8, 2023, the FDF published the first report on the expected impact of the implementation of the OECD minimum tax on the individual cantons as well as the planned measures of the individual cantons as of May 31, 2023.
Federal Council opens consultation on expanded loss offsetting
According to parliament, the loss offset period for companies is to be extended from seven to ten years. This is intended to enable companies affected by the Corona pandemic in particular to recover better. The Federal Council has drawn up the legal amendments for this and opened the consultation process at its meeting on June 28, 2023.
Tax-recognized interest rates 2023 for advances or loans in Swiss francs and foreign currencies
On February 7 and 8, 2023, the FTA published the Circulars on Swiss Franc and Foreign Currency Tax Recognized Interest Rates 2023.
Reporting concerning tax relief within the framework of regional policy
According to a media release, at its meeting on February 1, 2023, the Federal Council took note of a report by the Federal Department of Economic Affairs, Education and Research (EAER) on defining the areas of application for tax relief under regional policy.
FTA announces imputed interest rate on security equity 2023
On January 4, 2023, the FTA announced that the imputed interest rate on the security equity pursuant to the first sentence of Article 25abis(4) of the Tax Act, which is equal to the yield on 10-year federal bonds on the last trading day of the calendar year preceding the beginning of the tax period, is 1.565% for the 2023 tax year.
VST: Changes from January 1, 2023 in the reporting procedure in the group relationship
According to a communication from the Federal Tax Administration (FTA) dated December 23, 2022, the scope of the reporting procedure will be expanded as of January 1, 2023.
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Tax challenges for commercial real estate
Workshop by Robert Desax on the occasion of the ISIS) seminar on November 12, 2024 entitled "Tax challenges for commercial real estate"
Intragroup financing / Price adjustments / Transfer pricing and audits / Restructuring / Other current survey issues (part 1 and 2)
2-part workshop by Stefan Oesterhelt and David Tschan on the occasion of the ISIS) seminar on October 21, 2024 entitled "Intragroup financing / Price adjustments / Transfer pricing and audits / Restructurings / Other current survey issues" (Part 1 and 2)
Criminal withholding tax law - liability risks for directors and trustees/statute of limitations/intent
Workshop by Daniel Holenstein on the occasion of the ISIS) seminar on October 21, 2024 entitled "Criminal withholding tax law - liability risks for board members and trustees/statute of limitations/intent"
