Streamlined tax reporting: How Pillar II might provide you with an opportunity

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The OECD Global Minimum Tax regime (“GloBE”) is a headache for most organisations. Also known as Pillar II, the ruleset is complex and still moving, the data requirements to perform the calculations are far-reaching, and the timeline is ambitious. For impacted groups the implementation of a solution to this reporting challenge requires new resources with scarce skillsets.

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Posted on 12/04/2024 | 0 Comments

Cross-border posting of workers from and to Switzerland: A legal approach

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As Switzerland is not an EU-Member-State, the EU-PWD-Regulations are not applicable on postings from and to Switzerland. Instead, Swiss statutory law regulates the legal requirements as well as the applicable minimum standards for a posting to Switzerland and sets the mandatory notification process.

As different laws apply to the two models, the posting is to be differentiated from the staff leasing in Switzerland. This article provides a short overview on the distinctions between postings and staff leasing in Switzerland and delivers guidance for international assignments to companies.

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Posted on 11/04/2024 | 0 Comments

Swiss taxation of cryptocurrencies – Do withholding tax and stamp duties apply?

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Widespread adoption of cryptocurrencies and the increasing economic importance of digital assets increases the need to understand their respective tax implications. In Switzerland taxation of cryptocurrencies is usually based on existing tax laws. The Federal Tax Administration (FTA) has detailed its practice in a recently updated working paper.

Expanding on our previous blog post, this article provides a more in-depth analysis of withholding tax and stamp duty regulations regarding digital assets in Switzerland.

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Posted on 8/04/2024 | 0 Comments

Upcoming Revision of the Swiss VAT Law – Introduction of Annual VAT reporting and considerations regarding fiscal representation and joint liability of managing directors

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Continuing our series of blogs (n°1 & n°2) on the upcoming partial revision of the Swiss VAT Law (rVATL), which will come into force on 1 January 2025, this blog presents the main changes in the area of VAT compliance and administrative obligations.

As from 1 January 2025, companies registered for Swiss VAT will be able to report VAT on an annual basis.

The partial revision also introduces new rules to waive the obligation to appoint a fiscal representative for foreign taxpayers and joint liability for managing directors for VAT-related debts.

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Posted on 27/03/2024 | 0 Comments

Official launch of Limited Qualified Investor Funds in Switzerland on March 1, 2024

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With the enactment of the amended Collective Investment Schemes Act and Ordinance on March 1, 2024, the Limited Qualified Investor Fund (L-QIF) is now officially launched in Switzerland. As it does not require FINMA approval, it is an attractive, cost-efficient alternative to the Luxembourg RAIF, for example. The new scheme is restricted to qualified investors and must be managed by a regulated fund manager. However, like other collective investment schemes, it is also subject to the Swiss withholding tax, which makes it a less attractive option for international investors.

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Posted on 1/03/2024 | 0 Comments

Join our Global Employer Services webinar on 7 March 2024 at 10 am (CET)

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We would like to invite you to our upcoming webinar on Commuters between Switzerland and Italy: Update on income tax and social security rules.

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Posted on 29/02/2024 | 0 Comments

Between labour shortages and the desire to work part-time: ways out of the Swiss labour market crisis

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We are pleased to announce the release of the third article in our Pulse of Switzerland series, which highlights the current state of the Swiss labour market and offers insights into the attitude of employees with regards to their employability and part-time work. In light of the labour shortage crisis, the article addresses how both policymakers and companies can make gainful employment more attractive for mature workers, and how to increase the value of full-time work.

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Posted on 28/02/2024 | 0 Comments

Swiss Federal Tax Administration’s new Q&A on transfer pricing

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On 23 February 2024, the Swiss Federal Tax Administration ("SFTA") launched a new website on which the administration published its transfer pricing practice for the first time in the form of a Q&A. The website is initially available in German and French. This launch goes hand in hand with the recent transfer pricing paper published by the Swiss Tax Conference (see our blog). Which topics does the SFTA address (and which not), and how do Deloitte's transfer pricing experts assess the SFTA's newly published practice?

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Posted on 26/02/2024 | 0 Comments

OECD’s final Amount B report – game changer or complexify simplicity?

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On 19 February 2024, the Inclusive Framework on BEPS published its final report on Amount B of pillar one both in English and French, which provides a simplified and streamlined approach to the application of the arm's length principle to baseline marketing and distribution activities. This blog provides a summary of transactions in scope, the underlying transfer pricing method, the timing, and Deloitte Switzerland’s view.

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Posted on 20/02/2024 | 0 Comments

Upcoming revision of the Swiss VAT Law – Understanding the potential impact of the new e-commerce rules

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As announced in our previous blog, the Swiss Federal Council has confirmed that the partial revision of the Swiss VAT Law (rVATL), adopted by the Swiss Parliament in June 2023, will come into force on 1 January 2025. The revised law includes a wide range of changes, with the e-commerce rules one of the most significant.

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Posted on 15/02/2024 | 0 Comments

How US GAAP could influence tax reconciliation under IFRS

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Although it is a mandatory part of the notes to the financial statements, International Financial Reporting Standards (IFRS) do not specify the level of detail required in a tax reconciliation. In December 2023, the Financial Accounting Standards Board (FASB) issued new income tax disclosure requirements for US GAAP, in addition to modifying and eliminating certain existing requirements. Under the new guidance entities will be required to provide greater disaggregation of information in the rate reconciliation. Could these new US GAAP rules also affect income tax disclosures under IFRS?

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Posted on 13/02/2024 | 0 Comments