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  • Article

    Swiss Supreme Court Clarifies Illicit "Fishing Expeditions" In International Tax Assistance Procedures

    On July 23, 2015, the Dutch tax authorities filed with the Federal Tax Administration Agency in Switzerland a request for international tax assistance in order to identify prospective Dutch taxpayers through certain group criteria but w/o providing the specific names of those potential taxpayers.
    SwitzerlandTax
    Rihm Attorneys
    Rihm Attorneys
  • Article

    2024 Overview: Key Articles And Insights From Dixcart Switzerland

    As we approach the end of 2024, we reflect on the key articles shared by our Switzerland office this year. Below are concise summaries of Dixcart Switzerland's 2024 articles, offering practical
    SwitzerlandCorporate/Commercial Law
    Dixcart Group Limited
    Dixcart Group Limited
  • Article

    French Tax Authorities Do Not Benefit From HSBC Customer Data Stolen In Geneva

    The highest court in Switzerland now confirmed this latter view in a decision published last week.
    SwitzerlandTax
    Rihm Attorneys
    Rihm Attorneys
  • Article

    OECD-BEPS Measures In Swiss Double Tax Treaties - Impact Of The Principal Purpose Test

    The OECD published in October 2015 an action plan comprising 15 measures to fight base erosion and profit shifting (BEPS) of companies in the international tax environment.
    SwitzerlandTax
    Bär & Karrer Ltd.
    Bär & Karrer Ltd.
  • Article

    New Group Request From The Netherlands To The Swiss Tax Authorities

    On 6 February 2018, the Swiss Federal Tax Administration published a new group request received from the Dutch tax authorities based on Article 26 of the Double Taxation Agreement...
    SwitzerlandTax
    ALTENBURGER LTD legal + tax
    ALTENBURGER LTD legal + tax
  • Article

    Perceived Dividend Stripping Transactions – A Strange Decision Of The Swiss Federal Administrative Court

    The Swiss Federal Administrative Court issued an unusual ruling on dividend stripping transactions, raising questions about the interpretation and application of Swiss tax law in cross-border dividend scenarios. This decision examines the boundaries between legitimate tax planning and abusive practices in the context of international dividend distributions.
    SwitzerlandTax
    MME Legal | Tax | Compliance
    MME Legal | Tax | Compliance
  • Article

    New CH-I Agreement Announced Dealing With Teleworking Of Italian Frontier Workers Hired In Switzerland

    As mentioned in our briefing in February 2023, an extraordinary tax regime had been in place since June 2020 between Italy and Switzerland regarding the tax treatment of frontier...
    SwitzerlandTax
    Bär & Karrer Ltd.
    Bär & Karrer Ltd.
  • Article

    Switzerland Signs The BEPS-Convention

    The signing ceremony marks an important milestone in the international tax agenda and brings us closer to the goals defined in the BEPS Action Plan.
    SwitzerlandTax
    Bär & Karrer Ltd.
    Bär & Karrer Ltd.
  • Article

    Swiss Corporations: Stability In A Volatile World

    Recent events around the world, including the covid pandemic and major wars, mean that stability, security and reputational issues have become even more important
    SwitzerlandCorporate/Commercial Law
    Dixcart Group Limited
    Dixcart Group Limited
  • Article

    TRANSFER PRICING: Utilising the benefits of a low tax environment to implement transfer pricing related planning structures

    SwitzerlandInternational Law
    Pricewaterhouse Coopers
    Pricewaterhouse Coopers
  • Article

    Tax Incentives Under Pillar 2: New Opportunities Through Qualified Tax Incentives?

    The OECD/G20 global minimum tax (Pillar 2) has fundamentally altered how tax-based business location incentives function for multinational enterprises. The January 2026 Administrative Guidance introduces the "Substance-based Tax Incentive Safe Harbour" framework, creating new opportunities through Qualified Tax Incentives (QTIs) that may preserve economic benefits of certain tax incentives under Pillar 2 rules, though with important limitations tied to substance requirements.
    SwitzerlandTax
    Loyens & Loeff
    Loyens & Loeff
  • Article

    Swiss Voters Reject Introduction Of Swiss Federal Inheritance Tax – Current Cantonal Inheritance And Gift Tax System Remains Unchanged

    After a controversial political debate, the Swiss voters have decided to reject the popular initiative to introduce a federal inheritance tax with a vast majority of 71.7% in the popular vote of 14 June 2015.
    SwitzerlandTax
    Bär & Karrer Ltd.
    Bär & Karrer Ltd.
  • Article

    Payroll Challenges For Short-Term Assignments

    In today's globalized workforce, companies frequently assign employees on short-term international assignments to meet project needs, transfer knowledge, or support market expansion.
    European UnionEmployment and HR
    CONVINUS
    CONVINUS
  • Article

    Formation Of A Swiss Company And The Ability To Become Resident In Switzerland

    Switzerland is an attractive jurisdiction for the location of a company for several reasons, as detailed in the Dixcart Swiss Company Jurisdiction Note.
    SwitzerlandCorporate/Commercial Law
    Dixcart Group Limited
    Dixcart Group Limited
  • Article

    The Brazil And Switzerland Double Tax Treaty: Why Is It So Significant?

    The Brazilian and Swiss Governments signed a Double Tax Treaty (DTT) on 3 May 2018.
    SwitzerlandTax
    Dixcart Group Limited
    Dixcart Group Limited
  • Article

    Overlapping Taxation – A Special Aspect Of The Double Taxation Agreement Between Germany And Switzerland

    One particular aspect is without doubt "overlapping" taxation, which grants Germany unilateral taxation advantages.
    SwitzerlandTax
    CONVINUS
    CONVINUS
  • Article

    Formation Of A Swiss Company And The Ability To Become Resident In Switzerland

    Switzerland is an attractive jurisdiction for the location of a company for several reasons, as detailed in the Dixcart Swiss Company Jurisdiction Note.
    SwitzerlandTax
    Dixcart Group Limited
    Dixcart Group Limited
  • Article

    New Circular Letter On Lump-Sum Taxation In Switzerland

    In Switzerland, foreign wealthy families often benefit from special tax deals: lump-sum taxation or forfait fiscal in French.
    SwitzerlandTax
    Akin
    Akin
  • Article

    Remote Work And Permanent Establishments: Key Takeaways From The OECD 2025 Update

    The definition of a permanent establishment in Article 5(1) of the OECD Model Tax Convention remains unchanged. However, the Commentary now contains detailed guidance on when a home office, work performed in second...
    SwitzerlandTax
    Pestalozzi
    Pestalozzi
  • Article

    Residence and Taxation of Foreign Individuals in Switzerland

    Switzerland is a very attractive place of residence taxwise for EC nationals.
    SwitzerlandInternational Law
    Bachmann Trust Company Ltd.
    Bachmann Trust Company Ltd.
  • Showing 21–40 of 74 results

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