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.
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.
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.
Federal Council opens consultation on expanded loss offsetting
According to parliament, the loss offset period for companies is to be extended from seven to ten years. This is intended to enable companies affected by the Corona pandemic in particular to recover better. The Federal Council has drawn up the legal amendments for this and opened the consultation process at its meeting on June 28, 2023.
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.
ISIS) seminar folder "Corporate Tax Law (2025)"
All documents from the ISIS) seminar "Corporate Tax Law 2025" from June 02 + 03, 2025 under the direction of Peter Mäusli-Allenspach 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.
Transfer pricing documentation - International and Switzerland (2025)
Workshop by Ivo Manatschal, Simona Studer and Thomas Hug on the occasion of the ISIS) seminar on June 02 + 03, 2025 with the title "Transfer pricing documentation - International and Switzerland"
