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OECD Inclusive Framework reaches agreement on taxing the digitalized economy and a global minimum rate
On October 8, 2021 the OECD/G20 Inclusive Framework (“IF”) on base erosion and profit shifting (BEPS) issued a statement and an implementation plan (together, “the statement”) agreed by 136 of the 140 members of the IF outlining the political agreement with respect to the two pillar approach to address the tax challenges of the digitalization of the economy. Pillar One, Amount A, would reallocate profits of the largest and most profitable multinational enterprises (MNEs) to market jurisdictions; Pillar Two would impose a minimum tax on MNEs with gross revenues in excess of EUR 750 million and would require certain jurisdictions to agree to a subject to tax rule (STTR) in their treaties. A preliminary agreement had previously been announced in July. The two-pillar solution will be delivered to the G20 Finance Ministers meeting in Washington on October 13, then to the G20 Leaders’ Summit in Rome at the end of the month.
Join this year’s virtual Immigration Academy on Tuesday, 2 November 2021 from 2 p.m. to 4 p.m. The workshop will provide updates and discuss the latest developments in the field of immigration and remote working.
Brexit: Switzerland and the United Kingdom provide insights into recently negotiated bilateral Social Security Convention
On 11 August 2021 the Swiss Federal Council approved a new social security convention between Switzerland and the United Kingdom. It was officially signed by the Federal Council on 9 September and its provisional application was accepted by the Swiss parliamentary commissions. It is intended to apply this new convention provisionally from 1 November 2021, subject to the approval of the UK competent authorities. The new convention will enter into force definitively once both countries have ratified it.
This week the council of the EU adopted the position on public CbC reporting paving the way for final approval on the EU directive by the parliament in November. This implies that EU public CbCR might become reality for multinationals as early as 2023.
The revised Swiss Customs Act will scrap tariffs on industrial goods. This is good news for Swiss companies and consumers alike, as intermediary goods will become cheaper and customs clearance more effective and less costly.
Both chambers of Parliament (National Council and Council of States) have approved a revised text of the Swiss Customs Act. Formal endorsement is expected during the Parliament’s Autumn 2021 session, and entry into force should follow as of January 1st, 2022.
Nature equipped our trees with the astonishing ability to drop their summer leaves when fall approaches to get ready for a new start of our everlasting seasonal cycle. The US Internal Revenue Service (IRS) this year is in sync with nature and is ready to replace various W-Forms for the next season. The IRS published new draft Forms W-8BEN, W-8BEN-E, W-8IMY and W-8ECI between late August and early September 2021, as well as the corresponding draft instructions.
The International Tax Review (ITR), is a world recognised authority and publisher for tax professionals in industry, government, private practice and research and have just awarded Deloitte Switzerland with the accolades of being the Swiss Tax Firm of the Year and the Swiss Transfer Pricing Firm of the Year for the 9th time.
We would like to invite you to our upcoming event addressing the intersection between trade and financial sanctions on Tuesday 21 September at 15:30 (CEST) at our Deloitte premises, Rue du Pré-de-la-Bichette 1, 1202 Geneva.
The new Swiss-French convention on precious metal and multi-metal articles: An extended trade facilitation opportunity
As a positive example of enhanced cooperation, Switzerland and France have agreed to broaden the scope of their bilateral agreement on precious metals. The agreement now includes multi-metal goods.
Partnership withholding regulations: IRS defers the applicability date for certain provisions to 1 January 2023
After the publication of the final regulations under section 1446(f) of the US Internal Revenue Code in late 2020 (see prior blog post), the financial industry intensively lobbied for an extension of the applicability date.
On 24 August 2021, the Internal Revenue Service (IRS) announced in Notice 2021-51 that it intends to amend the regulations to defer the applicability date of certain provisions by one year to 1 January 2023.