Corporate Tax in Tax and Legal blog

Deloitte's Tax practice strengthens its capabilities for financial services, banking and insurance clients with two new key partners

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Deloitte Switzerland is delighted to announce that two new partners, Ilan Rom and Petrit Ismajli, will join its Financial Services Tax team on 1 December. This intake marks the continued strategic expansion of Deloitte`s tax-related services and capabilities for clients across the banking, insurance and investment management sectors.

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Posted on 1/12/2022 | 0 Comments

First EU member state issues Pillar II draft legislation

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On Monday 24 October 2022 the Netherlands published draft legislation, including commentary, relating to the domestic implementation of the global minimum tax (“Pillar II”). Essentially the draft legislation closely follows the OECD’s Pillar II Model Rules as well as the EU’s Pillar II directive proposal, containing the Income Inclusion Rule (“IIR”), Undertaxed Profits Rule (“UTPR”) and a Qualified Domestic Minimum Top-up Tax (“QDMTT”). It is expected that the IIR and QDMTT will come into effect for in-scope groups that have financial years starting on or after 31 December 2023. The draft legislation is open for public consultation until 5 December 2022.

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Posted on 26/10/2022 | 0 Comments

Join our OECD Pillar II tax accounting seminar in Zurich, 14 - 16 November 2022

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Registrations are closed – stay tune we are planning to repeat the seminar in spring 2023.

We would like to invite you to our OECD Pillar II/GloBE Tax Accounting seminar from Monday 14 to Wednesday 16 November 2022. Over this three half-day workshop series (1pm to 6pm), our team of local tax accounting and Pillar II experts will provide an interactive training taking you from the basics of tax accounting to understanding key considerations of Pillar II.

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Posted on 13/10/2022 | 0 Comments

Join our Financial Services tax webinar on 9 November 2022 at 08:30 to discuss legislative developments, court cases and practice

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We would like to invite you to our half yearly webinar where we provide key updates and discuss recent tax developments that are important for the financial services industry on Wednesday 9 November 2022 at 08:30.

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Posted on 10/10/2022 | 0 Comments

Swiss WHT Reclaims – A recent SFTA practice guidance on the statutory limitations provides clear guidance

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The Swiss Federal Tax Administration (SFTA) released a practice guidance on 13 September 2022 covering the refund of Swiss withholding taxes (Swiss WHT) on dividends and the applicable statutory limitations. The publication of the standardized practice is highly welcomed, as it provides clarity on how the SFTA determines the statute of limitations in a refund process.

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Posted on 5/10/2022 | 0 Comments

Public Vote Confirmed Swiss VAT Rate Increase and Rejected the Reform of Withholding Tax – What’s ahead?!

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VAT rate changes in Switzerland are quite common, mainly to finance “governmental projects”. The last VAT rate change took place in 2018. Based on our past experiences, we would generally expect the Swiss Federal Tax Administration (“SFTA”) to set transition rules covering both the tax point and resulting invoicing, as well as reporting rules. The key aspects mentioned hereinafter (subject to final publication and confirmation) will have to be considered from VATable persons in Switzerland.

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Posted on 26/09/2022 | 0 Comments

European push to implement Pillar II

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On Friday 9 September 2022 the governments of Germany, France, Italy, Spain and the Netherlands issued a joint statement confirming the intention to implement a global minimum tax (“Pillar II”). In essence, the statement mentions that even though EU-wide implementation of Pillar II is preferred (by means of an unanimously adopted EU Pillar II Directive), the countries will move forward with implementation even in the absence of an EU-wide agreement if such is not obtained over the coming weeks. The next ECOFIN meeting where Pillar II is on the agenda is scheduled for 4 October 2022.

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Posted on 12/09/2022 | 0 Comments

The global minimum tax roadmap: the fog begins to lift

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In July 2021, the G7 and the G20 fuelled the OECD Inclusive Framework with the consensus on the introduction of a global minimum tax of 15%. The high pace of policy leads at the OECD continued well into 2022 with the GloBE Framework (Pillar I & II) published in October 2021, the GloBE Rules (Pillar II) in December 2021 and the extensive commentary providing further guidance (March 2022). While the initial momentum provided for ambitious implementation plans, different global crises and the complexity of the implementation work required have slightly stalled progress. However, recent developments have revitalised the domestic efforts to introduce GloBE Rules and various jurisdictions have published their plans recently – among others: Switzerland.

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Posted on 24/08/2022 | 0 Comments

Corporate group financing from Liechtenstein

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Liechtenstein as business location

Liechtenstein is a small country in the heart of Europe, which offers a broadly diversified and stable business location with more than 4,800 active companies.

In the last ten years, Liechtenstein has successfully positioned itself as an onshore location for international groups. This can be seen, for example, in the proactive adoption by Liechtenstein of international developments in the tax area as part of its early adopter strategy and in the growing network of double taxation agreements. Nevertheless, Liechtenstein has managed to continue to offer favorable tax planning options in selected areas.

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Posted on 23/05/2022 | 0 Comments

How is your organisation responding to current tax transformation trends?

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Our last tax transformation trends survey report, in a series of three, has been issued. While the first two reports focused on transformation trends in tax operations and workforce, this last issue is centred on tax technology. This blog aims at highlighting key findings of the reports series.

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Posted on 19/05/2022 | 0 Comments