The diminishing safeguard function of the withholding tax
Editorial on the focus issue "Withholding Tax" of zsis).
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.
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.
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.
FTA publishes circular no. 29c "Capital contribution principle
The FTA published Circular No. 29c "Capital Contribution Principle" on December 23, 2022.
FTA publishes tax statistics for individuals and legal entities 2019
On November 3, 2022, the FTA published the 2019 tax statistics.
FTA publishes interest rates for direct federal tax 2023
On October 13, 2022, the Federal Tax Administration (FTA) published the - unchanged - interest rates for the 2023 direct federal tax:
Update of the areas of application for tax relief
On October 10, 2022, the Federal Department of Economic Affairs, Education and Research (EAER) adopted an amendment to the "Ordinance of the EAER on the Determination of the Municipalities Included in the Areas of Application for Tax Relief" for the purpose of updating the areas of application for tax relief under regional policy.
Droit pénal fiscal en matière d'impôt anticipé et de droits de timbre
Workshop on the occasion of the ISIS) seminar of 14 November 2018 entitled "Droit pénal fiscal et rappel d'impôt
Tax issues and tax planning for permanent establishments
Workshop on the occasion of the ISIS) seminar of 27 September 2018 entitled "Value Added Tax. Current. Compact. Interdisciplinary."
Taxation of investments in securities in Switzerland - including structured products, collective investments and segregation of private and professional asset management
Workshop on the occasion of the ISIS) seminar on 10-11 September 2018 entitled "Taxation of investments in securities in Switzerland
