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Swiss authorities have published new guidance on the country’s language requirements for residence permits.
What does the change mean?
Dependent spouses of non-EU/EFTA B-permit holders, B-permit holders seeking renewal and certain C-permit applicants may be required to demonstrate a higher level of language proficiency in the primary language of their place of residence at the time of registration or most recent residence after 12 months in Switzerland.
The Swiss Common Reporting Standard (CRS) implementation set to change after Global Forum recommendations
The Swiss Federal Council began the consultation on amendments to the Swiss Common Reporting Standard (CRS) Law and Ordinance on 27 February 2019. The amendments follow recommendations made by the Global Forum on Transparency and Exchange of Information for Tax Purposes (Global Forum). The consultation period lasts until 12 June 2019 and the amended CRS Law and Ordinance are scheduled to become effective as of 1 January 2021. Read on for an overview of the most important changes.
On 10 January 2019, the UK tax authorities, HM Revenue & Customs (HMRC) launched a new Profit Diversion Compliance Facility (PDCF) for multinational enterprises (MNEs) using cross-border arrangements targeted by Diverted Profits Tax (DPT). DPT was introduced in April 2015 to tackle the diversion of profits from the UK to low tax jurisdictions.
The PDCF gives MNEs the opportunity to review the design and implementation of their transfer pricing policies, analyse DPT and any other tax risks and, if necessary, bring their tax position up to date by submitting a disclosure report with a proposal to pay any additional tax, interest and potentially penalties due.
In July 2017, the Chief Executive of the UK Financial Conduct Authority (FCA) announced that firms should discontinue the use of the London Interbank Offered Rate (LIBOR) in favour of overnight risk-free rates (RFRs). Although registered and administered in the UK, LIBOR is a benchmark that underpins contracts affecting banks, asset managers, insurers and corporates globally. The transition must be completed by the end of 2021, as the continuation of LIBOR will not be guaranteed to market participants after that date.
The Swiss Federal Council has approved the bilateral post-Brexit agreement. The agreement has yet to be ratified by the U.K.
What does the news mean?
The new Swiss-U.K. agreement will administer the status of U.K. nationals in Switzerland and Swiss nationals in the U.K. following Brexit.
The Swiss Federal Council has approved a temporary quota scheme which will be allow UK nationals to apply for work authorization in Switzerland after Brexit.
On 23 January 2019, the Swiss Federal Tax Administration (FTA) published revised CRS guidance notes. The update mainly incorporates previously released guidance and disappointingly only contains limited material amendments. In addition, several examples (e.g. on the identification of controlling persons) and explanations (e.g. on the wider approach) were removed, without changing the underlying rules and thus having a limited impact. Finally, a number of linguistic errors and references were corrected, one of which also resulted in a re-release on 28 January 2019. Read on for a summary of the most important changes for Swiss financial institutions (FIs).
New withholding tax practice further increases the attractiveness of Switzerland as an international financing and treasury center
The funds flow back to Switzerland from a bond of a foreign issuer guaranteed by a Swiss parent (downstream guarantee) will no longer attract Swiss withholding tax on the interest, as long as such funds flow does not exceed, either, the aggregate equity of foreign affiliates, or, the aggregate loans to foreign affiliates.
Investing in the United States? Join us and learn more at our OFII breakfast event on 15 March, Zurich
Our breakfast event highlights:
- Investment landscape in the US: a political, legislative and regulatory perspective
- US tax reform a year later: a US inbound perspective
- The growing importance and complexity of state taxes for US inbound investors
- Navigating the changing US inbound environment: a headquarters perspective
Register and join our first-ever Deloitte Immigration Academy in Geneva on Thursday, 21 March.
The Academy is a new Deloitte initiative bringing global mobility, immigration and HR professionals in Switzerland together to learn about and discuss the most current and important immigration topics. It is a half-day workshop that combines technical training, a group discussion and a short presentation by topic experts. The content is based on real-life case studies with a focus on sharing practical experience on how best to address today’s immigration challenges.
Since BEPS, multinational companies are operating in an environment of unprecedented complexity. The rising volume and variety of intercompany transactions and transfer pricing regulations, coupled with increased tax authority collaboration across borders present both risks and opportunities. Our transfer pricing updates will provide you with the latest transfer pricing issues and developments worldwide that may affect your business.