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.
The FTA has updated the statistics on the capital contribution principle (November 2021)
The Federal Tax Administration (FTA) has updated the statistics on the capital contribution principle (capital contributions, repayments and other changes) as of 30 September 2021.
Federal Council sets voting date for referendum against the amendment to the Stamp Duty Act
On 13 October 2021, the Federal Council set the referendum proposals for 13 February 2022. Among them is the referendum on the abolition of the emissions levy.
FTA publishes notice on liquidation of collective investment schemes (investment funds)
In its communication dated 30 August 2021, the FTA provided information on the procedure for liquidating collective investment schemes (investment funds).
Recognised data suppliers (for the turnover tax) as of 1 July 2021 according to the FTA
The FTA informs about the data providers recognised for the turnover tax as of 1 July 2021.
WAK of the National Council supports the draft of the withholding tax reform by a large majority
In its media release of 18 August 2021, the WAK of the National Council provided information on the withholding tax reform bill.
New Form 12 FL for the declaration of the insurance stamp by Liechtenstein policyholders
A new Form 12 FL concerning the self-declaration of stamp duty on insurance premiums / insurance with a foreign insurer by Liechtenstein policyholders was published on 9 July 2021.
Transactions et restructurations de sociétés de personnes en matière d'impôts
Cas pratiques présentés par Laïla Rochat et Paul Penin lors du séminaire ISIS) du 03 novembre 2021 intitulé "Restructurations / Fusions / Acquisitions".
Impôts directs: Fusion, scission et transfert intra-groupe
Cas pratiques présentés par Jean-Marie Hainaut et Jean Ebener lors du séminaire ISIS) du 03 novembre 2021 intitulé "Restructurations / Fusions / Acquisitions".
Seminar folder ISIS)-Seminar "Change of Status, Patent Box and R&D Effort in Practice" (2021)
Case studies, detailed solutions and slides: Here you will find all documents (workshops and presentations) according to the following description from the ISIS seminar "Status change, patent box and R&D expenditure in practice" on 21 September 2021 under the direction of René Matteotti and Jürg B. Altorfer.
