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.
Adjustment SSK-KS 28: New calculation of the capitalization rate and clarification regarding start-up companies
The Swiss Tax Conference published an updated version of SSK-KS 28 on 3 November, which concerns the calculation of the capitalisation rate for determining the capitalised earnings value and a clarification of the practice for the valuation of start-up companies.
Federal Council wants to exempt too-big-to-fail instruments of banks from withholding tax by the end of 2026
At its meeting on 28 October 2020, the Federal Council adopted a dispatch on the Federal Act on Withholding Tax with regard to the treatment of interest on too-big-to-fail instruments (TBTF).
FTA publishes update to circular no. 37 "Taxation of employee shareholdings
On 30 October 2020, the FTA published an update to Circular Letter No. 37 "Taxation of Employee Participation".
Canton of Zurich: New information sheet on the additional deduction for research and development expenses
On 25 September 2020, the cantonal tax office in Zurich published a new information sheet on the additional deduction for research and development expenses.
Tax policy agenda: First meeting of the "Expert Group on Switzerland as a Tax Location
On behalf of Finance Minister Ueli Maurer, a tax policy agenda is to be adopted by the end of 2020.
FTA publishes Circular Letter No. 49 "Proof of business-related expenses for foreign transactions abroad" and Circular Letter No. 50 "Inadmissibility of tax deduction of bribes paid to public officials".
On 13 July 2020, the FTA published Circular No. 49 "Evidence of business-related expenses for foreign-foreign transactions" and Circular No. 50 "Inadmissibility of the tax deduction of bribes paid to public officials". At the same time, the predecessor circulars of the same name, No. 9 of 22 June 2005 and No. 16 of 13 July 2007, are repealed.
Block chain and distributed ledger technology: No changes to tax law
At its meeting on 19 June 2020, the Federal Council took note of the report on a possible need to adapt tax law in the area of block chaining. The report comes to the conclusion that there is no need for specific legislative adjustments in tax law.
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"
