Basel Plans to Strengthen its Attractiveness as a Life Sciences Business Location

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After the cantons of Grisons and Zug (see recent blog), the canton of Basel-City has now also presented its plans to strengthen its economic attractiveness. The package includes measures in the areas of innovation, society, and the environment as well as tax compensation measures. The focus is clearly on promoting the key life sciences industry. The trend in all cantons so far is towards location promotion outside the tax system and it is unclear whether the Qualified Refundable Tax Credits (“QRTC”) instrument will become established in Switzerland.

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Posted on 26/06/2024 | 0 Comments

Are you ready to comply with the Swiss implementation of the crypto information exchange standard CARF?

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As one of the first countries, Switzerland published its draft legislation for the domestic implementation of the OECD’s Crypto-Asset Reporting Framework (CARF). In particular, on 15 May 2024, the Swiss authorities launched a combined consultation on CARF and the amendments to the Common Reporting Standard (CRS 2.0), proposing respective additions and amendments to the Automatic Exchange of Information (AEI) Act and Ordinance. The consultation runs until 6 September 2024, and new and amended rules are anticipated to come into force on 1 January 2026. While this blog focuses on the Swiss CARF implementation, we will publish a second blog shortly focusing on CRS 2.0 and the more general aspects of the consultation.

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Posted on 25/06/2024 | 0 Comments

Federal Supreme Court ruled on Income Tax Treatment of Treasury Shares

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In a long-awaited landmark decision, the Federal Supreme Court (“Bundesgericht”) has ruled on the question of whether the reissue of treasury shares by a company is subject to corporate income tax. The court concluded that no taxable capital gains arise from the reissue of treasury shares since there is no legal basis in the tax law to deviate from the treatment in the financial statements (9C_135/2023, in German). Despite this important decision, however, the Federal Supreme Court has not yet clarified all aspects.

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Posted on 24/06/2024 | 0 Comments

Join our Deloitte's Pillar 2 Technology Showcase - Explore leading Pillar 2 solutions

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Sign up for our upcoming event where you will have the opportunity to access Pillar 2 solutions demos, meet with the Pillar 2 solution vendors teams and network with your peers.

The event will take place on the following dates and locations:

  • Geneva - Wednesday, 19 June 2024
  • Zurich - Thursday, 4 July 2024

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Posted on 5/06/2024 | 0 Comments

Swiss Equity Incentive Reporting – Struggling with Equity Annexes?

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Swiss tax law requires employers who incentivise employees with equity- based compensation, settled either in cash or in equity, to provide the tax administration with a summary of the taxable amounts, exchange rates used and other information. Even in the absence of any transaction, a yearly recap must be provided to the authorities. When equity awards are taxed across multiple jurisdictions the summary also needs to include the calculation method used to allocate taxing rights and determine the exact amount of Swiss taxable income.

This summary document is commonly called an “equity annex” and needs to be delivered at the same time as the Swiss salary certificate. Many employers often struggle to gather the information, prepare the annex and deliver it on time to employees.

However, there are automated reporting solutions that can make this process easier.

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Posted on 4/06/2024 | 0 Comments

Court Rejects Zurich Practice to Levy Real Estate Capital Gain Tax on Shareholders in Germany

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In a recent court case (GR.2023.22, in German) the Zurich Tax Appeals Court ("Steuerrekursgericht Zürich") confirmed that the sale of the majority of shares in a Swiss real estate company by a German domiciled individual constitutes a sale of financial assets, even though the sale qualifies as an indirect sale of real estate (change of economic ownership) under Zurich tax law. In view of the double taxation treaty between Switzerland and Germany and according to the prevailing academic consensus, the right to tax the capital gain was granted to Germany. As a result, the relevant city in the canton of Zurich does not have the right to levy the real estate capital gain tax on the indirectly sold property. The court decision is not yet legally binding.

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Posted on 30/05/2024 | 0 Comments

Join our Swiss Advisory Roundtable: Latest updates on individual tax, social security and immigration

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Sign up for our next Swiss Advisory roundtable "Latest updates on individual tax, social security and immigration – Spotlight: From hiring to ending: tax, social security and employment law aspects for executives” in:

  • Zurich - Thursday 6 June
  • Geneva – Tuesday 11 June
  • Basel – Tuesday 18 June

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Posted on 22/05/2024 | 0 Comments

Canton of Zug Plans to Strengthen its Attractiveness in a Post-Pillar II World

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The canton of Zug aims to strengthen the attractiveness of Switzerland, and in particular the canton itself, as a business location in a post-Pillar II world using a bundle of instruments with a focus on subsidies related to sustainability and innovation (media release in German). No Qualified Refundable Tax Credits (“QRTC”) are planned at this stage. The consultation draft of the "Location Development Act" is subject to a popular vote in 2025 and would come into force on January 1, 2026.

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Posted on 17/05/2024 | 0 Comments

New Climate Protection Ordinance creates incentives to tackle net-zero targets

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On 18 June 2023 the Swiss electorate approved the Climate Protection and Innovation Act (CPA). The act was accepted as counterproposal to the popular Glacier Initiative and is set to take effect on 1 January 2025. The CPA mandates that Switzerland should achieve net-zero emissions by 2050 in the building, transport, and industrial sectors. To achieve this objective, the CPA provides that the Swiss State will offer funding to companies that develop and utilise innovative technologies. The specific details of these funding programmes and incentives are outlined in the Climate Protection Ordinance (CPO), whose consultations have just ended, on 1 May 2024.

This blog focuses on the funding available to companies pursuing innovative technologies and briefly discusses the eligibility criteria, explores the projects that meet the qualifications for funding, and outlines the process to become eligible for funding.

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Posted on 17/05/2024 | 0 Comments

Training your chatbot correctly – What are the legal implications of a chatbot that provides wrong information?

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The emergence of new technologies, including the widespread use of artificial intelligence in everyday life, has significantly affected the legal landscape. The use of chatbots in online contracting, coupled with the now well-known phenomenon of artificial intelligence hallucinations – incorrect or misleading results derived from AI – has resulted in novel challenges, notably in the realm of contract law. As a result, the courts and tribunals must adapt to this new reality and grapple with issues such as determining liability where a customer contracts on the basis of inaccurate information provided by a chatbot on a company’s website.

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Posted on 16/05/2024 | 0 Comments

Upcoming revision of the Swiss VAT Law – introduction to the changes for government, public services and non-governmental organisations

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We continue our series of blogs (n°1, n°2, n°3, n°4) on the upcoming partial revision of the Swiss VAT Law (rVATL), which will come into force on 1 January 2025. In this blog, changes related to government, public services and non-governmental organisations are discussed.

From January 1, 2025, a new definition of the concept of a subsidy and amendments relating to VAT exempt without credit supplies will be included in Swiss VAT law.

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Posted on 15/05/2024 | 0 Comments