Tax and Legal blog
Stay up to date with the latest tax and legal issues and developments that may affect you and your business.
Incoming Trump Presidency and the Potential Tax Impact for US Persons in Switzerland
As the US prepares for President-elect Donald Trump to take office on January 20, 2025, the United States is preparing for significant shifts in tax policy. With Republicans controlling both chambers of the US Congress, and many individual income tax provisions of the Tax Cuts and Jobs Act of 2017 (TCJA) sunsetting at the end of 2025, the stage is set for potential tax changes that will impact businesses, individuals, and the broader economy. For Americans living abroad, these changes could have significant implications and allow for new planning opportunities.
Swiss Immigration Update: A review of 2024 and preview of upcoming changes in 2025
As we enter 2025, we would like to reflect on the past 12 months, summarise the developments, look ahead to the new year, and elaborate on expected changes from an immigration perspective.
Share Grants under Incentive Plan not Subject to Securities Transfer Duty
In a decision published before Christmas (9C_168/2023 and 9C_176/2023, in French), the Federal Supreme Court addressed whether the grant of shares to managers without consideration under a management incentive plan established by a Swiss holding company is subject to Swiss Securities Transfer Duty. The court concluded that, subject to certain conditions, no Securities Transfer Duty is to be levied.
Pillar Two Registration in Switzerland as of 1 January 2025
With the operational launch of the web-based application OMTax on 1 January 2025, companies in Switzerland will be able to fulfil their legal obligation to register for Pillar Two purpose. Registration will be exclusively electronic and must be completed at the latest before filing the tax return (typically by 30 June 2026). If a multinational group has several entities in Switzerland, a responsible entity must be designated for registration. However, this cannot be freely chosen but must be determined based on legal requirements.
Swiss Immigration Update: Switzerland releases work permit quotas for 2025
The Swiss government has set work permit quotas for non-EU/EFTA nationals, UK nationals and EU nationals on assignment. Furthermore, as of January 2025, Croatian Nationals will not longer be subject to Swiss quotas.
Switzerland published draft law to extent tax loss period
The Federal Council (“Bundesrat”) published its draft law and the accompanying dispatch on the extension of the tax loss carry-forward period from seven to ten years (media release: German/French), but at the same time recommended that the proposal be rejected. What are the chances of this proposal being adopted by the Swiss Parliament?
Transforming Transfer Pricing Operations: A refreshed perspective
As the financial year draws to a close, businesses often face a myriad of challenges, particularly in the realm of operational transfer pricing (OTP). Ensuring compliance with transfer pricing (TP) regulations while maintaining optimal operational efficiency can be a complex balancing act. Companies must navigate through stringent documentation requirements, fluctuating market conditions, and the need for accurate intercompany pricing adjustments.
This blog post series delves into understanding what OTP is all about, the common hurdles encountered and offers insights on how to effectively manage OTP to achieve both regulatory compliance and business objectives.
Securities Transfer Duty Relief for Group Companies Acting as Intermediaries
The Swiss Federal Tax Administration (“SFTA”) issued a practice note (German/French) clarifying the topic of group holding or management companies acting as intermediaries mainly in an M&A transaction in view of the securities transfer duty. The new practice applies with immediate effect to all pending cases and will lead to a relaxation in this controversial topic.
Join us on 5 December 2024 in Zurich for an event on the Crypto-Asset Reporting Framework (CARF)
As the adoption of crypto assets continues to grow, the need for clear and standardized tax regulations has become essential. As of 1 January 2026, the Crypto-Asset Reporting Framework (CARF), the new information exchange regime focusing on crypto transactions, will come into force. CARF aims to enhance transparency and compliance surrounding the taxation of crypto assets by clarifying the responsibilities of different service providers involved in crypto-related transactions.
The end of the transition period for companies limited by shares – is your company compliant?
On 1 January 2023 the reform of Switzerland’s legislation on companies limited by shares came into force, responding to the current economic environment and needs. Companies incorporated after this date have been required to comply with the new provisions from the outset. Those already in existence on the date were granted a two-year transition period to adapt their articles of association. With that transition period set to expire on 31 December 2024, the aim of this blog post is to provide an overview of the most relevant changes.