Corporate Tax in Tax and Legal blog

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

Swiss taxation of cryptocurrencies – how are investors taxed?

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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.

This series of blogs will focus on explaining the income and wealth tax implications for owning and trading digital assets, the tax consequences for VAT, stamp duties and withholding tax, as well as taxation at issuer level.

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Posted on 16/01/2024 | 0 Comments

It’s official: Switzerland to implement Pillar 2 in a gradual approach

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The Federal Council decided at its meeting today that Switzerland will introduce the global minimum tax (“Pillar 2”) in a gradual approach. Specifically, from 1 January 2024, Switzerland will levy a national top-up tax (QDMTT) on profits of Swiss corporations and permanent establishments of international groups. The international top-up tax (IIR, UTPR) on profits of foreign subsidiaries and permanent establishments of Swiss headquartered groups will be introduced at a later stage (potentially 1 January 2025). What does this decision mean in detail?

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Posted on 22/12/2023 | 0 Comments

Why obtaining Transfer Pricing certainty also becomes important for Pillar II?

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The purpose of the blog is to discuss the importance of obtaining Transfer Pricing certainty from the perspective of the Pillar II rules (GloBE / QDMTT rules). Failure to obtain certainty on Transfer Pricing positions could expose the MNE Group to double taxation not only in the current corporate income tax framework but potentially also double taxation / over taxation because of the interaction of the current corporate income tax / transfer pricing framework with the new Pillar II system.

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Posted on 10/11/2023 | 0 Comments

Deloitte Switzerland's Tax & Legal practice strengthens its capabilities with Thomas Hug joining as Partner

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Deloitte Switzerland is delighted to announce that Thomas Hug joined its Tax & Legal team as Partner on 1 November. This intake marks the continued strategic expansion of Deloitte`s tax-related services in the Swiss marketplace.

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Posted on 1/11/2023 | 0 Comments

Join our OECD Pillar Two/GloBE Tax Accounting seminar in Zurich, 20 – 22 November 2023

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We would like to invite you to our OECD Pillar Two/GloBE Tax Accounting seminar from Monday 20 to Wednesday 22 November 2023 in the Deloitte office in Zurich. Over this three half-day workshop series (1pm to 6pm), our team of local tax accounting and Pillar Two experts will provide an interactive training taking you from the basics of tax accounting to understanding key considerations of Pillar Two.

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Posted on 10/10/2023 | 0 Comments

CBAM: are you ready to comply?

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1. What is CBAM?
The Carbon Border Adjustment Mechanism (CBAM) is a regulation pushed by the EU in the context of the EU Green Deal.
Under CBAM, Importers into the EU must pay a financial adjustment for the emissions released during the production of certain carbon-intensive goods in third countries.
The goal of the legislation is to mitigate the risk of carbon leakage and ensure the effectiveness of EU climate measures.

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Posted on 4/10/2023 | 0 Comments

Is your company following the current tax transformation trends?

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Through a survey of 300 senior tax and finance leaders across a variety of regions and industries, Deloitte has identified certain tax transformation trends impacting the tax and finance teams of large multi-national enterprises.

First of all, data and cost management are still priorities for heads of tax. However, there is now a clear focus on tax-related systems integrations and the adaptations needed to comply with the changing tax regulatory landscape, driven, in particular, by the OECD Pillar 2 regime.

Also, as technology is evolving quickly and becomes a “must have”, companies are exploring different strategies to access technology capabilities, including through outsourcing,

Finally, technology is also a key capability sought in new tax staff hires, where there is a race for the “unicorn” profiles, combining industry knowledge, tax savviness and data/IT expertise.

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Posted on 19/09/2023 | 0 Comments

Update of the Geneva practice on the taxation of management incentive plans

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On July 3, 2023, the Geneva tax authorities (GTA) published on their website an amendment to the way in which they tax management incentive plans.

The new amendment increases the scope for beneficiaries of management incentive plans to receive benefits in a more tax efficient way.

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Posted on 24/07/2023 | 0 Comments

Global Minimum Tax: Swiss voters pave the way for implementation in 2024

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In the popular vote on 18 June 2023, Swiss voters approved the most extensive change to the Swiss corporate tax system in over a century with a wide majority. With the amendment of the Swiss constitution the Swiss voters have paved the way for the Swiss legislator to introduce the global minimum tax (also referred to as “Pillar II”) in Switzerland.

Pillar II introduces an additional layer of taxation (tax law) to Swiss constituent entities of multinational enterprises in scope of the rules and introduces a corporate group taxation system in Switzerland with a mandatory tax of 15% that is determined under a new tax basis (“GloBE”).

The magnitude of change is significant and will redefine the Swiss corporate tax environment in the years to come.

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Posted on 19/06/2023 | 0 Comments