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.
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.
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.
