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.
Income and withholding tax: Determination of the maximum permissible conversion discount
On April 22, 2025, the FTA published notice 024-DVS-2025 regarding the determination of the maximum permissible conversion discount.
Supplementary tax: Tax treatment of business units that qualify as permanent establishments
On March 18, 2025, the FTA explained the treatment of business units that are considered permanent establishments in a communication on the minimum taxation of multinational enterprise groups.
FTA publishes circular no. 32a: Reorganization of corporations and cooperatives
On January 20, 2025, the FTA published circular no. 32a regarding the "Restructuring of corporations and cooperatives".
FTA publishes imputed interest rate on the security equity 2025
The imputed interest rate on the security equity corresponds to the yield on ten-year federal bonds on the last trading day of the calendar year preceding the beginning of the tax period in accordance with Article 25abis paragraph 4 first sentence StHG.
Federal Council adopts dispatch on the extension of loss offsetting
On November 27, 2024, the Federal Council adopted the dispatch on extending loss offsetting from seven to ten years.
Practical specifications for sales tax for brokerage activities within a group relationship
Recent case law in the area of sales tax for intermediaries in a group relationship has prompted the FTA to make clarifications in its administrative practice regarding Art. 13 para. 1 and Art. 13 para. 3 lit. b no. 2 StG. The two practical clarifications will be applied with immediate effect and will apply to all cases currently pending with the FTA.
Fringe benefits / private shares / expenses / hidden profit distributions
Workshop by Franziska Spreiter and Christian Vassalli at the ISIS) seminar on 13/14 September 2021 entitled "Employee compensation in tax and social security law".
Withholding taxes - What to focus on in the new law?
Workshop by Birgitte Zulauf and Abramo Lo Parco on the occasion of the ISIS) seminar on 13/14 September 2021 entitled "Employee compensation in tax and social security law".
