Refund of withholding tax under the new Art. 23(2) VStG - an interpretative regulation
The reimbursement of withholding tax to domestic recipients of services requires, among other things, that the income subject to withholding tax and the assets on which it is based are declared "in an orderly manner".
Tax rulings - Swiss success model at risk?
Tax rulings are omnipresent in Swiss tax consulting. With the StAhiV, they have been incorporated into Swiss legislation for the first time as of 1 January 2017 and are referred to there as "preliminary tax assessments", about which other states must be informed in certain situations. Recently, the courts have also been increasingly concerned with questions relating to tax rulings.
ISIS Tax Talks 2018: Accounting and Taxation of Crypto Issues
The accounting and taxation of crypto items was the focus of the ISIS Tax Talks on 20 November 2018 in Zurich-Oerlikon. Mr. Matthias Langer, LL.M., tax consultant and partner of actus ag in Liechtenstein, provided the audience with an overview of the challenges that arise in practice with regard to digital currencies. Prof. Dr. iur. Peter Mäusli-Allenspach, LL.M., lic. iur. HSG Thomas Linder, federally certified tax expert, and lic. iur. Stephan Stauber, lawyer and head of the tax administration of the Canton of Basel-Stadt, participated in the subsequent discussion on the topic.
Value added tax in the annual financial statements - general information for practical application realization
The MWSTG includes standards for the clean recording of VAT in the annual financial statements, which must be observed. This article deals with the relevant standards of accounting law and refers to the current decision of the Federal Administrative Court on value added tax. The correct recording of turnover tax and input tax and the guarantee of the audit trail are important prerequisites for VAT compliance.
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 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.
Federal Council enacts Federal Act on the Taxation of Telework as of 1.1.2025.
At its meeting on October 16, 2024, the Federal Council decided to bring the Federal Act on the Taxation of Teleworking into force on January 1, 2025.
New circular no. 6a: Hidden equity capital
On October 10, 2024, the FTA published the updated circular no. 6a regarding "Hidden equity".
Taxes in the cost-plus method - FTA publishes statement on the ruling of the Federal Supreme Court 9C_37/2023
In its ruling 9C_37/2023 of June 11, 2024 (see our article), the Federal Supreme Court addressed, among other things, the question of whether or not the tax expense should be taken into account in the cost base when applying the cost-plus method in the context of Art. 58 para. 3 DBG.
FTA - Notification withholding tax: Declaration of reserves from capital contributions
On September 18, 2024, the FTA clarified the administrative practice in accordance with item 9 of circular no. 29c on the capital contribution principle dated December 23, 2023 regarding the declaration of reserves from capital contributions.
International supplementary tax IIR to come into force in 2025
At its meeting on September 4, 2024, the Federal Council decided to bring the Income Inclusion Rule (IIR) into force on January 1, 2025. In addition to the QDMTT, which was already introduced on January 1, 2024, this rule is intended to ensure that tax revenue remains in Switzerland.
Transitional solution for the too-big-to-fail instruments for withholding tax
At its meeting on August 21, 2024, the Federal Council approved a temporary extension of the special regulations for interest from TBTF instruments until December 31, 2031. Without an additional extension, interest on TBTF instruments issued after December 31, 2026 would be subject to withholding tax.
tax due diligence
Workshop on the occasion of the ISIS) seminar on 27 October 2020 entitled "Tax pitfalls in Mergers & Acquisitions transactions".
ISIS) seminar "Practical cases on withholding tax and outlook on current developments" (seminar folder)
Case studies, detailed solution notes and slides: Here you will find all documents (workshops and presentations) according to the following description from the ISIS) seminar "Practical cases on withholding tax and outlook on current developments" of 21.09.2020 under the direction of Thomas Jaussi, which took place in the Marriott Hotel in Zurich.
