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There have been concerns lately that the German tax authorities might seek to tax certain extraterritorial royalty payments associated with German intellectual property (IP). Although the potential for extraterritorial tax has existed under Germany’s tax rules for a number of years, the possibility that these rules might be applied to certain structures has only recently become known. Whether the tax rules will be applied to specific transactions will depend on the facts and circumstances in each case.
Changing course: Tax policy implications of a Joe Biden presidency - Join our webcast on 10 November
For the first time since 2014, Income Taxes will be a focus area for SIX for 2020.
In particular, for IFRS reporters, the reconciliation from the applicable to the effective tax rate (or tax expense) will be under scrutiny, as well as the effective tax rate itself. The focus will be placed on whether the information provided is meaningful, comprehensive and appropriately explained.
For FER financial statements, scrutiny will be focused on the disclosures with regard to the applicable tax rate, the impact from variations in tax loss carry forwards and deferred income tax entitlements for unused tax loss carry forwards.
The Swiss Federal Council published the consultation draft regarding the Swiss withholding tax reform and the abolishment of Swiss securities transfer tax on debt instruments
On 3 April 2020, the Swiss Federal Council released a proposed set of amendments to the Swiss withholding tax and securities transfer tax regimes. The reform primarily aims at strengthening the Swiss debt capital market and increasing tax honesty of Swiss resident individual investors.
The consultation period runs until 10 July 2020 and the rules will become effective as early as 2023.
This Roadmap provides Deloitte’s insights into and interpretations of the income tax accounting guidance in ASC 740 and the differences between that standard and IFRS® Standards (in Appendix F) and reflects Accounting Standards Updates (ASUs) issued by the FASB through 31 December 2019.
We are glad to announce our new Swiss focused COVID-19 Tax & Legal impact website, which features a wealth of readily accessible content to help our Swiss clients manage and mitigate the risks associated with COVID-19.
The Swiss COVID-19 Tax & Legal impact website
In addition to the large scale health threat, the COVID-19 outbreak is heavily impacting economic activity, leading the Swiss government to take measures to help businesses deal with and mitigate the sizeable impact. will be updated on a frequent basis so that you can stay in tune with the latest developments.
On 20 March 2020, the Federal Council announced a comprehensive package of measures to mitigate the economic consequences of the COVID-19 pandemic. One of these measures was the introduction of government-guaranteed loans from Swiss banks as an interim measure for Swiss small and medium sized enterprises (“SMEs”), including sole proprietors and partnerships by providing them with sufficient liquidity to cover their current fixed costs despite a COVID-19 related loss of turnover. The federal government expects to provide Swiss SME’s with approx. CHF 20bn in financing to cover liquidity shortages in the coming weeks.
Swiss tax authorities are participating in the widespread effort of countries and support Swiss taxpayers.
As part of the countries masterplan and stimulus package to counter the economic impact of the Covid-19 pandemic, the Swiss Federal Government provides for a number of tools to keep liquidity going:
Listen to the webcast recording and explore the opportunities to create a digital-ready tax function
Changes to the tax legislative landscape mean that compliance and reporting is becoming more immediate, digitalised and data intensive. To respond, tax teams need accurate data, captured and calculated right first time. But data, processes and systems are often not supportive of tax requirements, so how can tax leaders react effectively to these new challenges?