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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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.
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Reporting procedure in group relationships, reimbursement in national relationships - current practice and rulings
Workshop by Markus Küpfer at the ISIS) seminar on October 21, 2024 entitled "Reporting procedures in group relationships, reimbursement in national relationships - current practice and decisions"
Focus on procedural law
Workshop by Thomas Jaussi on the occasion of the ISIS) seminar on October 21, 2024 entitled "Focus on procedural law"
ISIS) seminar folder "Withholding tax practice and outlook on current developments (2024)"
All documents from the ISIS) seminar "Withholding tax practice and outlook on current developments" held on October 21, 2024 under the direction of Thomas Jaussi 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.
