Latest Development On Withholding Tax Refund Requirements

Among the distinctive features of the Swiss tax system is a particular regime designed for affluent foreign individuals who relocate to Switzerland.

Switzerland's federal tax structure creates significant regional variation in corporate and personal taxation, offering businesses and individuals strategic planning flexibility. With effective corporate tax rates ranging from 11.9% to 20.5% and personal income tax rates varying between 22.2% and 43.2% across cantons, location choice becomes a critical factor in tax optimization.

Switzerland's shift to individual taxation by 2032 will fundamentally reshape the country's lump-sum taxation regime for internationally mobile individuals. The reform removes the requirement that both spouses must qualify simultaneously for lump-sum taxation, creating new planning opportunities for mixed-status couples while introducing complexities around asset allocation and minimum tax thresholds.

On 8 March 2026, Swiss voters approved the Federal Act introducing individual taxation, with 54.3 % voting in favour. This marks a fundamental shift in the taxation of individuals: going forward, all persons...

The Swiss withholding tax is a pivotal aspect of Switzerland's taxation system, particularly for foreign investors. This tax is levied on various types of income originating in Switzerland...

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...

System change as of 2029: The imputed rental value will be abolished, and at the same time maintenance and energy-saving deductions for owner-occupiers will be eliminated. Value-preserving investments should therefore be carried out by the end of 2028.

As Switzerland's first QDMTT assessments arrive following the 30 June 2026 filing deadline, taxpayers face complex interpretive questions around the GloBE Model Rules. With no prior Swiss court rulings on Pillar Two matters, this analysis examines the procedural pathways and substantive grounds available for challenging disputed positions, from cantonal objections through federal administrative and supreme court appeals.

For many years, there have been efforts to eliminate the unequal tax treatment of married and unmarried couples, commonly referred to as the “marriage penalty”. The inequality lies in the fact that, under current law, the income and assets of a married couple are aggregated for income and wealth tax purposes, respectively, whereas this is not the case for unmarried couples.

Generally, interest paid on loans are not subject to Swiss Withholding Tax ('WHT'). Interest on bonds and bank interest, however, are subject to 35% Swiss WHT

Over the past decades, the increasing internationalization and commercialization of professional football competitions have attracted a growing number of investors seeking to acquire stakes in football clubs.

Swiss parent companies with Russian subsidiaries face mounting risks as Russia increasingly places foreign-owned entities under temporary administration, following recent actions against Nestlé, Danone, Carlsberg...

System change as of 2029: The imputed rental value will be abolished, and at the same time maintenance and energy-saving deductions for owner-occupiers will be eliminated. Value-preserving investments should therefore be carried out by the end of 2028.

Swiss companies and investors are navigating a rapidly evolving ESG regulatory landscape. In the recent past, non-financial reporting duties for large public interest companies...

The primary methods of presenting factual evidence in international arbitration are contemporaneous documents, testimony of fact witnesses and testimony...

Systemwechsel ab 2029: Der Eigenmietwert entfällt, zugleich fallen Unterhalts- und Energiesparabzüge für Selbstnutzer weg. Werterhaltende Investitionen sind deshalb bis Ende 2028 vorzunehmen.

In a long-awaited decision, the Cantonal Court of Zug ("Court") on 17 December 2025 declared the climate lawsuit brought by four Indonesian islanders ("Plaintiffs")...

Nach der kürzlich in Kraft getretenen Revision der für Banken und Versicherungen anwendbaren Gesetze soll die Verordnung über Insolvenz...

Switzerland is introducing a central, non-public Transparency Register of the beneficial owners of Swiss companies.

For Switzerland, the most important international treaties are the WTO's Agreement on Government Procurement (GPA) and the Agreement between...