Tax Blog
Stay up to date with the latest tax issues and developments that may affect you and your business.
BREAKING NEWS: US Senate approved Swiss-US double tax treaty protocol
On July 17, 2019, the US Senate approved the long-overdue 2009 protocol to the Swiss-US double tax treaty, the core element of which concerns administrative assistance.
Formally, the protocol will enter into force once the instruments of ratification are exchanged, which is likely to happen in the course of the coming months.
DAC6 for banks – thoughts and examples
The latest amendment to the EU’s Directive on Administrative Cooperation (“DAC6”) requires EU intermediaries (and in certain cases relevant EU taxpayers) to report on cross-border tax arrangements that are potentially aggressive or abusive, so-called “reportable cross-border arrangements” (RCBAs).
This blog is part of a series designed to help our clients react to the new requirements during this time when the guidance is still evolving by sharing our experiences. This particular blog discusses selected banking offerings that potentially qualify as RCBAs and require reporting by banks or their customers.
The first step towards simplifying the taxation on private use of business vehicles
On 28 June 2019, the Federal Department of Finance published for consultation an amendment to the ordinance dealing with the business expense deductions for employees.
This adjustment intends to reduce the administrative burden for employers and employees in situations where employers provide company cars to employees.
Join our Business Travellers Event to discuss challenges in the Financial Services Industry on 11 September, Geneva
Register and join our Business Travellers Event with a focus on the Financial Services Industry on Wednesday, 11 September 2019 in Geneva. We will discuss the current regulatory and compliance landscape for international business travellers.
What is the event about?
- Global trends driving increased risk in relation to business travel;
- The growing regulatory burden on employers and employees, and the increased efforts by authorities to enforce these regulations;
- Steps employers are taking to monitor business travel risks and improve governance; and
- Current market best practice - prioritising compliance risks, quantifying costs and addressing duty of care considerations;
- Permanent establishment risks in relation to business travel.
IFRS tax accounting impact of Swiss Tax Reform
On May 19, 2019 the Swiss public voted to adopt the Federal Act on Tax Reform and AHV Financing (“TRAF”) confirming the reform of corporate taxation in Switzerland.
The EXPERT Suisse published a Q&A on July 2, 2019 related to the IFRS tax accounting implications of the reform. For companies reporting under IFRS, we recommend reviewing the Q&A to for guidance on the impact, including re-measurement of the deferred taxes and potential disclosures in their 2019 Financial Statements which may already be applicable.
The Swiss Federal Council kicks off Swiss withholding tax reform
On 26 June 2019, the Swiss Federal Council informed about its intentions to reform the Swiss withholding tax system. The need for such a reform is two-fold: Firstly, the reform aims at strengthening the Swiss debt capital market. Secondly, it strives to increase tax honesty of Swiss resident individual investors.
The key parameters established by the Swiss Federal Council in its 1.5-page communication partially piggyback on the ideas presented in an expert board’s report early this year, which was discussed in a prior blog post.
The Swiss Federal Council mandated the Federal Department of Finance to prepare a consultation draft, which should be available in autumn.
DAC6: The clock is ticking… Less than 1 year until go-live
The latest amendment to the EU’s Directive on Administrative Cooperation (“DAC6”) requires EU intermediaries (and in certain cases relevant EU taxpayers) to report on cross-border tax arrangements that are potentially aggressive or abusive, so-called “reportable cross-border arrangements” (RCBAs).
After the go-live on 1 July 2020, DAC6 will require reporting within 30 days after the start date of a new RCBA. In addition, DAC6 includes a retroactive element requiring reporting of all arrangements going back to 25 June 2018 by 31 August 2020.
Even though member states are still transposing the Directive into local law, affected institutions should kick off their implementation efforts now. Delaying implementation bears the risk of not being ready in time for the first reporting and will additionally increase the review backlog for RCBAs subject to the retroactive reporting obligation.
Start spreading the news: Updates from the Kaplan tax conference in New York
The annual International Tax & Information Reporting Conference in New York represents an opportunity for industry to hear from the IRS and discuss tax technical challenges.
Hosted over two days in New York on the 5th and 6th of June, as active participants, Deloitte AG were able to hear first-hand the hot tax topics affecting US and non-US financial institutions.
So what were the key messages communicated by IRS representatives and what are challenges facing the financial services community? This blog summarises the key messages from the conference.
New Tax at Source legislation - what do employers and employees have to prepare by 1 January 2021?
In April 2018, the Swiss government announced that the new tax at source law, which was adopted in December 2016, is to enter into force on 1 January 2021.
This has prompted the Federal Tax Administration (FTA) to publish circular letter 45. This letter explains the new tax at source law in detail and attempts to clarify certain topics with an ultimate goal of harmonising different cantonal practices.
Global Transfer Pricing Update: May 2019
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.
Join our Industry Solutions for Global Trade Roundtable on 27 June in Basel
Are you still struggling with generic customs solutions, which do not fit your industry specific flows? At Deloitte we recognise that each industry has particular requirements, driven by the products it offers, the customers it serves and the increased regulations it must comply with. Therefore, together with SAP we invite you to join our Industry Solutions for Global Trade Roundtable.