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Further to the partial revision of the current Swiss Value Added Tax (VAT) Law (VAT-L), foreign domiciled companies operating in the distance selling business will be equated with companies domiciled in Switzerland.
The Common Reporting Standard (CRS) released by the OECD requires Reporting Financial Institutions (FIs) to obtain the Tax Identification Number (TIN) of certain clients. This confronts FIs with a number of practical challenges. The main areas of concern are the validation of TINs obtained and how to deal with clients who claim being unable to provide a TIN. Unfortunately, regulators do not address this topic in detail. Thus, Reporting FIs should not only consider regulatory requirements but also operational and strategic aspects when developing policies and implementing the necessary processes.
The US Treasury Department and Internal Revenue Service (IRS) have been busy providing new guidance for foreign financial institutions (FFIs), qualified intermediaries (QIs) and qualified derivatives dealers (QDDs) in the last weeks.
Since BEPS, multinational companies are operating in an environment of unprecedented complexity. The rising volume and variety of intercompany transactions and transfer pricing regulations, coupled with increased tax authority collaboration across borders present both risks and opportunities. Our transfer pricing updates will provide you with the latest transfer pricing issues and developments worldwide that may affect your business.
IRC Section 871(m) final and temporary regulations became effective on 1 January 2017, heralding a new era of withholding tax with respect to derivatives referencing at least one US equity. Issuers of such products were busy over the last months collecting data to finalize their QDD application, and dealing with issues surrounding the withholding on dividend equivalent payments.
The Swiss Parliament is currently debating major changes to Swiss pension law, notably one whereby retirees will only be able to receive their pension in the form of a life annuity and no longer as a lump-sum distribution.
On June 7, 2017 Switzerland signed the Multilateral Agreement on the implementation of tax related measures against Base Erosion and Profit Shifting (BEPS). The Agreement will allow Switzerland to adapt double taxation agreements to the minimum standards as agreed under the OECD BEPS project. Switzerland will implement these minimum standards either under the MLI or through bilateral negotiations of double taxation agreements.
On June 7, 2017 Switzerland signed the Multilateral Agreement (MLI) on the implementation of tax related measures against Base Erosion and Profit Shifting (BEPS). The Agreement will allow Switzerland to adapt double taxation agreements (DTAs) to the minimum standards as agreed under the OECD BEPS project.
As part of its 2017 budgetary measures, the Belgian legislator expanded the scope of the stock exchange tax (taxe sur les opérations de bourse or Beurstaks), colloquially known as the TOB, to cover transactions executed on behalf of Belgian residents through non-Belgian financial intermediaries. The amendment may have significant implications for Swiss banks, brokers and wealth managers processing financial transactions for the benefit of Belgian tax residents.
We are pleased to present our 2017 edition of the Living and working in Switzerland brochure, which has been prepared to provide you with an overview of some of the important issues that may affect foreign nationals moving to Switzerland.
Tax authorities have begun to focus not only on punishing tax evaders, but also on targeting the intermediaries that facilitate tax evasion. The G7 Bari declaration of 13th May re-emphasised this approach, with an added focus on those who seek to circumvent the new Common Reporting Standard (CRS) requirements.