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On 10 October 2018, the OECD issued the 2017 mutual agreement procedure (MAP) statistics, which provide detailed information regarding the MAP activities of 85 OECD and G20 jurisdictions. According to the OECD, the statistics show that even though tax administrations are closing an increasing number of cases, the total number of cases in inventory continues to rise.
"We do not provide tax advice. You should consult your own tax advisor before engaging in any transaction." We expect that all readers are familiar with the above disclaimer banks make when making financial recommendations. In this article, we seek to understand why banks are reluctant to provide tax advice and, more importantly, why they should not be.
The Swiss Tax Conference which is an organisation with representatives from both the Swiss cantonal and federal tax authorities recently updated their “Swiss salary certificate frequently asked questions” (FAQ) publication.
The new FAQ states that (i) income from equity compensation must always be reported in total on the Swiss salary certificate and (ii) any international allocation of income has to be shown in a company attested addendum to the benefitting employee’s yearly Swiss salary certificate.
What Swiss FIs must know about the abolition of the “white list” approach in the Swiss CRS legislation
On 22 October 2018, the Swiss Federal Tax Administration (SFTA) published an FAQ announcing that Switzerland intends to amend the participating jurisdiction definition in the CRS Ordinance by abolishing the “white list” approach. Once approved by the Federal Council, the changes will become effective on 1 January 2019 and impose additional due diligence obligations on Swiss financial institutions (FIs).
This blog discusses the legislative change announced in the FAQ, sets out the scope of affected jurisdictions and highlights the key tasks and considerations for Swiss FIs in complying with the amendment.
IRS representatives participated in several panels at the 33th Annual Forum Tax Withholding & Information Reporting Conference (11-12 October 2018) and the SIFMA Global Tax Reporting Symposium (16-17 October 2018), where they shared insights and responded to questions relevant for US and non-US financial institutions.
This blog summarizes the key messages communicated by IRS representatives during these significant industry conferences, that have historically preceded the issuance of new guidance and outlines the potential impact to non-US financial institutions.
Were you aware of the new Swiss job notification requirements and how it has affected the recruitment process for Swiss employers?
Take the opportunity to be part of the new job notification requirement: 2-minute Survey and share your thoughts to help us understand how these new requirements have impacted the recruitment process for Swiss employers in the first three months after implementation.
As digitisation progresses, organisations are asking themselves to what extent business-relevant documents may be digitally archived and whether physical archiving can be completely dispensed with. Swiss law lacks a uniform regulation of the retention and archiving of business documents. Consequently, the question if the documents may be retained in electronic form to comply with applicable legal provisions cannot be answered with a general statement. Additionally, procedural considerations may have an impact on the decision.
This article provides a short overview of what organisations need to consider when shifting from paper to electronic document retention.
Employees are seeking more flexibility than ever before in relation to their working arrangements. At the same time, employers need to leverage the value of their global workforce whilst operating in an ever-changing complex global environment.
Join us at the International Morning at the Salon RH Suisse conference at Palexpo Geneva on Wednesday 3 October, where Ross Hamilton, Director in the Global Employer Services team at Deloitte Switzerland will be speaking about some of the key disrupters that present new challenges and opportunities for organisations as they seek to ensure that they have both an agile and effective global workforce.
On 5 July 2018, the U.S. Treasury Inspector General for Tax Administration (“TIGTA”) released a final report which found that, despite spending nearly $380 million, the U.S. Internal Revenue Service (“IRS”) has taken limited or no action on a majority of planned activities to enforce compliance with the Foreign Account Tax Compliance Act (“FATCA”). While the report does address findings and recommendations regarding U.S. taxpayer compliance, it includes a number of findings and recommendations relevant for foreign financial institutions (“FFI”), of which FFIs need to be mindful when considering potential future IRS enforcement focus areas.
The Treasury and the IRS on September 13 released proposed regulations addressing the new Global Intangible Low-Taxed Income (GILTI) provision of the 2017 tax law. The regulations are 157 pages long and generally apply to taxable years of foreign corporations beginning after 31 December 2017, and to taxable years of U.S. shareholders in which or within which such taxable years end. However, certain provisions have different effective dates. The regulations are a mixture of anti-abuse provisions as well as mechanical provisions that deal with calculation issues.