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.
Transfer of the registered office to Switzerland - A case for the old reserve practice?
The problem of old reserves has become an integral part of daily tax consulting practice in Switzerland. The corresponding problem will be examined in this article on the basis of a transfer of the registered office of a foreign company to Switzerland. Here, too, the Federal Tax Administration (FTA) initially assumed that the "old reserves" brought into Switzerland were subject to Swiss abuse practice without restriction.
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.
Circular No. 5a Restructuring
The new circular no. 5a on tax-neutral reorganisations was published on 1 February 2022. The following key adjustments were made in the circular:
Tax-approved interest rates 2022 for advances or loans in Swiss francs and in foreign currencies
On 27 January 2022, the FTA updated the circular on the tax-recognised interest rates in Swiss francs, and on 28 January 2022, the circular on the recognised interest rates 2022 in foreign currencies.
OECD Minimum Tax: Implementation with a Constitutional Amendment
On 13 January 2022, the Federal Council announced that it would like to implement the agreed minimum tax for certain companies with a constitutional amendment. A temporary ordinance is to ensure that this can come into force on 01 January 2024. Subsequently, the law will be enacted through the ordinary legislative process.
FTA announces imputed interest rate on security equity 2022
On 6 January 2022, the FTA announced that the imputed interest rate on the security capital pursuant to Art. 25abis para. 4 sentence 1 StHG, which corresponds to the yield on 10-year federal bonds on the last trading day of the calendar year preceding the start of the tax period, will continue to be 0% for the 2022 tax year due to the negative yield.
Dossier on tax information "Cryptocurrency" published
The FTA has published a new article "Cryptocurrency" for the tax information dossier.
FTA publishes updated working paper on cryptocurrencies and ICOs/ITOs
The FTA has updated its working paper on cryptocurrencies and initial coin/token offerings (ICOs/ITOs) as a subject of wealth, income and profit tax, withholding tax and stamp duties. It reflects the state of practice as of the end of 2020.
Adaptation of the leaflet of the cantonal tax office on the taxation of banks and securities houses
The Zurich Cantonal Tax Office has published an updated leaflet on the taxation of banks and securities houses (ZStB No. 64.2).
Federal Council rejects abolition of stamp duties on sustainable financial products
The Federal Council has approved the report entitled "Releasing the brakes on sustainable financial products". The report concludes that the abolition of stamp duties on sustainable financial products is not expedient.
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.
