Implementation of the tax reform and AHV financing (STAF) in the canton of Solothurn and first practical experiences
With the adoption of the STAF by the Swiss electorate on 19 May 2019, the cantonal tax privileges were abolished in all cantons as of 1 January 2020 and replaced by instruments that are internationally accepted. While the Solothurn electorate approved the STAF at federal level with 58.6% of the vote, it simultaneously rejected the first cantonal proposal to implement the STAF, which would have provided for a significant reduction in the profit tax rate, with 51.4% of the vote. In the second proposal, which was accepted by the electorate, it was possible to agree on a less extensive, but still substantial, reduction of the profit tax rate. For the city of Solothurn, for example, the effective profit tax rate for legal entities will be 15.29% from 2022 (previously: 21.23%). In addition to this reduction in the profit tax rate and the legislative changes prescribed by the Federal Act on the Harmonisation of Direct Taxes of the Cantons and Municipalities (StHG), individual provisions of the Tax Act were adapted to the new accounting law with the implementation of the STAF in the Canton of Solothurn and accompanying measures were adopted in the area of natural persons.
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.
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.
STAF enters into force on 1 January 2020
According to a press release dated 14 June 2019, the Federal Law on Tax Reform and OASI Financing (STAF) will come fully into force on 1 January 2020.
STAF - Abolition of the federal practices for principal companies and Swiss Finance Branches
As part of the implementation of the STAF, the Federal Tax Administration (FTA) will no longer apply the federal practices for principal companies and Swiss Finance Branches from 1 January 2020.
Adoption of the tax reform and AHV financing (STAF) (referendum of 19 May 2019)
After the Corporate Tax Reform III (USR III) was rejected in February 2017, Swiss voters voted on the tax reform and AHV financing (STAF). The proposal was accepted by the people and cantons with around 66% (cf. preliminary official final results).
Clarification of legal information and preliminary tax assessments (tax rulings)
On 29 April 2019, the Federal Tax Administration (FTA) published details of the code of conduct for the provision of legal information and rulings in the areas of value added tax and corporate tax for radio and TV as well as tax rulings for direct federal tax, withholding tax and stamp duties.
FDK publishes survey results on the implementation status of STAF in the cantons
The Conference of Cantonal Finance Directors (FDK) published the results of a survey on the updated implementation status of the Federal Law on Tax Reform and OASI Financing (SV17 / STAF) in a communication dated 10 May 2019.
Federal Council initiates consultation on STAF regulations concerning the deduction of interest on capital and foreign withholding taxes
On April 10, 2019, the Federal Council sent the ordinances for the implementation of STAF (tax reform and AHV financing) for consultation.
Reimbursement in international circumstances - current practice and problem areas
Workshop by Oliver Oppliger on the occasion of the ISIS) seminar on October 21, 2024 entitled "Restitution in international relations - current practice and problem areas"
Criminal withholding tax law - liability risks for directors and trustees/statute of limitations/intent
Workshop by Daniel Holenstein on the occasion of the ISIS) seminar on October 21, 2024 entitled "Criminal withholding tax law - liability risks for board members and trustees/statute of limitations/intent"
Intragroup financing / Price adjustments / Transfer pricing and audits / Restructuring / Other current survey issues (part 1 and 2)
2-part workshop by Stefan Oesterhelt and David Tschan on the occasion of the ISIS) seminar on October 21, 2024 entitled "Intragroup financing / Price adjustments / Transfer pricing and audits / Restructurings / Other current survey issues" (Part 1 and 2)
ISIS) seminar folder "Corporate Tax Law 2024"
All documents from the ISIS) seminar "Corporate Tax Law" from June 3 - 4, 2024 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.
