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.
Overview of STAF implementation at federal and cantonal level
Following an unprecedented legislative process, the Swiss people adopted the Federal Law on Tax Reform and OASI Financing (STAF) on 19 May 2019, thus restoring international acceptance of our tax system. In addition to the abolition of the special regulations for status companies, the introduction of the patent box, the regulation for hidden reserves at the start of tax liability and the approval of special deductions for research and development have helped to strike the right balance between international acceptance and maintaining the attractiveness of the tax location.
The implementation of the STAF in the cantons of Eastern Switzerland - selected topics of profit and capital taxation
The eastern Swiss cantons of St. Gallen (SG), Thurgau (TG), Appenzell Ausserrhoden (AR) and Appenzell Innerrhoden (AI) have implemented a number of changes in the taxation of profits and capital as part of the STAF as of 1 January 2020. The present article examines individual voluntary measures and measures not harmonized in the STAF. The analysis focuses on the adjustments in profit tax rates and capital tax, past and future tax relief, the additional deduction for research and development expenses, and a selection of special practical features.
Implementation of the STAF in the Canton of Zurich
Although the Canton of Zurich dealt with the implementation of the Federal Law on Tax Reform and OASI Financing ("STAF") at an early stage and issued various practice notes, various implementation issues still arose in the months following its entry into force. This article deals with the current implementation practice of STAF in the Canton of Zurich, with a focus on the change of status and deductions for self-financing. The practical application of the patent box and the research and development deduction is still subject to announcements by the Zurich tax office.
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 template 17 is linked to AHV restructuring
Tax Bill 17 will be linked to the AHV restructuring. This was decided by the Council of States. This approach is intended to help the corporate tax reform achieve a breakthrough and relieve the burden on old-age pensions.
Tax submission 17 (12 April 2018)
The Committee for Economic Affairs and Taxes of the Council of States (WAK-S) has already unanimously agreed to tax bill 17 at its meeting on 12 April 2018. At its meeting on 15 May 2018, the WAK-S unanimously supported an overall concept with the following four central elements:
Deductibility of fines and penalties
In its decision of 26 September 2016, the Federal Supreme Court had to rule on a case concerning the tax law admissibility of a provision in connection with an EU cartel fine. The affected X. AG filed an appeal against the decision of the Cantonal Tax Office of Zurich with the Tax Appeal Court of the Canton of Zurich, which upheld the appeal. The cantonal tax office appealed unsuccessfully against this decision to the Administrative Court of the Canton of Zurich, which dismissed the appeal in its ruling of 9 July 2014 on both state and municipal taxes and direct federal taxes. The cantonal tax office then lodged an appeal with the Federal Supreme Court in matters of public law.
Pitfalls with mobile employees and global employee participation program
Workshop by Sandro Di Giulio and Alain Friedrich at the ISIS) seminar on November 16, 2022 entitled "Pitfalls with mobile employees and global employee participation programs"
Crypto in employee participation programs
Workshop by Stéphanie Fuchs and Noëmi Kunz-Schenk on the occasion of the ISIS) seminar on May 22, 2022 entitled "The world of work on the move: tax and social security law challenges"
ISIS) seminar folder "Exchange of services between affiliated companies (2025)"
All documents from the ISIS) seminar "Exchange of services between affiliated companies" from February 05, 2025 under the direction of Thomas Hug 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.
