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Proposed changes to the Qualified Intermediary agreement introduce burdensome requirements to collect US TINs
This blog is the second of a two-part series and discusses the due diligence challenge linked to a Qualified Intermediary (QI) holding Publicly Traded Partnership (PTP) interests in custody for non-US investors as of 1 January 2023 when the new PTP withholding regulations come into force: the collection of non-US investors’ US TINs for purposes of §1446(a) and §1446(f).
You can access here our first blog in this series which addressed QI difficulties in complying with electronic reporting obligations via FIRE due to new US TIN requirements introduced for identity verification purposes.
Deloitte's Tax practice strengthens its capabilities for financial services, banking and insurance clients with two new key partners
Deloitte Switzerland is delighted to announce that two new partners, Ilan Rom and Petrit Ismajli, will join its Financial Services Tax team on 1 December. This intake marks the continued strategic expansion of Deloitte`s tax-related services and capabilities for clients across the banking, insurance and investment management sectors.
Swiss Immigration Update - Switzerland and United Kingdom Extend the Services Mobility Agreement (SMA)
Switzerland and the United Kingdom (UK) have jointly agreed to extend the terms and conditions outlined in the Services Mobility Agreement (SMA) for another three- years until December 31st, 2025. UK-based companies can therefore continue to make use of the online notification procedure and obtain short-term work permits to post service providers to Switzerland.
The Swiss Federal Council has reacted to the high number of Croatian workers who have entered the Swiss labour market since the beginning of this year and has decided to invoke the ‘safeguard clause’ for Croatia. Therefore, as of 1 January 2023, Swiss employers will be required to make sure that a work permit is granted to Croatian nationals before they take up employment in Switzerland. For Swiss employers this will mean longer processing times for Croatian workers and a possible impact on planned start dates in 2023.
Corruption sanctions are the new political weapon of the EU to thwart kleptocratic behaviour and illicit money flows globally. The continuing trend towards values-based sanctions, such as corruption sanctions, shows a strong inclination on the part of like-minded governments to pursue an interconnected due diligence approach. Ursula von der Leyen, President of the European Commission, announced that the EC will prioritise defending European values abroad by introducing corruption sanctions. This calls for European companies, including Swiss ones, to ensure that their Sanctioned Party List (SPL) screening and Business Partner Due Diligence (BPDD) set-ups are up to date, interdisciplinary, complete, and reliable. Companies may have to rethink their country risk ratings.
Sanctions are more than just a trend and sanction compliance is now a new reality for Swiss businesses. While authorities and businesses in the US and the EU have gained experience on these topics over the last decades, the Swiss market has only recently started adapting to the ever-changing geo-political and sanction landscape.
The latest draft of the French finance bill for 2023 foresees that employment income received by French residents from a non-French employer would no longer be subject to the monthly tax at source withholding obligation in France.
On Monday 24 October 2022 the Netherlands published draft legislation, including commentary, relating to the domestic implementation of the global minimum tax (“Pillar II”). Essentially the draft legislation closely follows the OECD’s Pillar II Model Rules as well as the EU’s Pillar II directive proposal, containing the Income Inclusion Rule (“IIR”), Undertaxed Profits Rule (“UTPR”) and a Qualified Domestic Minimum Top-up Tax (“QDMTT”). It is expected that the IIR and QDMTT will come into effect for in-scope groups that have financial years starting on or after 31 December 2023. The draft legislation is open for public consultation until 5 December 2022.
Join our insightful upcoming VAT Hybrid breakfast event on 16 November in Zurich and/or follow-up apéro on 23 November in Geneva
We would like to invite you to our upcoming VAT Breakfast Event which will provide an update on recent Swiss and international VAT developments and upcoming changes. The event will take place on Wednesday 16 November 2022 in our Zurich office as well as online.
During its autumn 2020 session the Swiss Parliament adopted the new Act on Federal Data Protection (hereafter "nFADP"). It represents a complete overhaul of data protection legislation, necessary because there has been significant technological change in recent decades. It was also necessary to align with European legislation.
The nFADP and its ordinances (Ordinance on Data protection (hereafter "OPDo") and Data Protection Certifications (hereafter "OCPD")), will come into force on 1st September 2023 and will replace the current FADP of 1992.
Registrations are closed – stay tune we are planning to repeat the seminar in spring 2023.
We would like to invite you to our OECD Pillar II/GloBE Tax Accounting seminar from Monday 14 to Wednesday 16 November 2022. Over this three half-day workshop series (1pm to 6pm), our team of local tax accounting and Pillar II experts will provide an interactive training taking you from the basics of tax accounting to understanding key considerations of Pillar II.