Corporate Tax in Tax and Legal blog

Canton of Zug Plans to Strengthen its Attractiveness in a Post-Pillar II World

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The canton of Zug aims to strengthen the attractiveness of Switzerland, and in particular the canton itself, as a business location in a post-Pillar II world using a bundle of instruments with a focus on subsidies related to sustainability and innovation (media release in German). No Qualified Refundable Tax Credits (“QRTC”) are planned at this stage. The consultation draft of the "Location Development Act" is subject to a popular vote in 2025 and would come into force on January 1, 2026.

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Posted on 17/05/2024 | 0 Comments

Federal Supreme Court to lower level of evidence in (intercantonal) tax law

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In a new leading decision by the Federal Supreme Court (9C_591/2023, in German), the five judges have spoken out in favour of lowering the level of evidence in (intercantonal) tax law. The decision, which is intended for official publication, means that in tax law the requirements for providing evidence are lowered for the tax administration (and conversely raised for taxpayers). What are the consequences for taxpayers in Switzerland?

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Posted on 22/04/2024 | 0 Comments

Streamlined tax reporting: How Pillar II might provide you with an opportunity

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The OECD Global Minimum Tax regime (“GloBE”) is a headache for most organisations. Also known as Pillar II, the ruleset is complex and still moving, the data requirements to perform the calculations are far-reaching, and the timeline is ambitious. For impacted groups the implementation of a solution to this reporting challenge requires new resources with scarce skillsets.

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Posted on 12/04/2024 | 0 Comments

Swiss taxation of cryptocurrencies – Do withholding tax and stamp duties apply?

Tax and Legal blog

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.

Expanding on our previous blog post, this article provides a more in-depth analysis of withholding tax and stamp duty regulations regarding digital assets in Switzerland.

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Posted on 8/04/2024 | 0 Comments

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?

Tax and Legal blog

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