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The International Tax Review (ITR), is a world recognised authority and publisher for tax professionals in industry, government, private practice and research and have just awarded Deloitte Switzerland with the accolades of being the Swiss Tax Firm of the Year and the Swiss Transfer Pricing Firm of the Year for the 9th time.
On 10 July the G20 endorsed the key components of the two pillar approach to international tax reform that was recently endorsed by 132 countries and jurisdictions, constituting the vast majority of the OECD/G20 Inclusive Framework (“inclusive framework”) on Base Erosion and Profit Shifting (BEPS). Each of the two pillars addresses a separate concern.
OECD Inclusive Framework reaches political agreement on taxing the digitalised economy and a global minimum rate
Since 2017, the 139 member countries of the Inclusive Framework have been jointly developing a ‘two-pillar’ approach to address the tax challenges arising from the digitalisation of the economy. This led to the publication of two detailed ‘Blueprints’ in October 2020 on potential rules for addressing nexus and profit allocation challenges (‘Pillar One’) and for global minimum tax rules (‘Pillar Two’). The proposals were updated and simplified by the US Biden Administration in April 2021, and formed the basis for the political agreement reached by the G7 countries in June 2021.
Switzerland, located geographically in the heart of Europe is associated with mountain peaks rather than a global maritime reach. However the country has one of the largest maritime merchant fleets in the world (11th in size globally, close behind the UK).
To strengthen the attraction of Switzerland to companies that operate and manage maritime activities, the Swiss Federal Government recently issued a consultation draft with regard to the introduction of a ‘tonnage tax concept’. The proposed (simplified) law is that the taxable ‘profit’ of eligible companies would be based on cargo volume (‘net tonnage’) rather than operating profits or volume of cargoes carried. The tax would be optional, and companies could choose instead to be taxed by current methods.
New disruptive and constantly evolving technology is rapidly transforming businesses. Companies are investing in big data, automation, and artificial intelligence solutions to enhance their business capabilities. The 2020 pandemic has also forced companies to accelerate the existing digitalisation plans to have data and processes continuously available and operable in a secure manner to ensure continuity of the business.
A ‘future ready’ tax function needs tax data management and analytics resources at its fingertips to support the business. S/4HANA provides both, the key is understanding how to use it to ensure your data is right first time and aligned to your business needs, whilst improving your control environment to fulfil tax compliance - without huge manual effort. How can your organisation improve it’s data organisation?
The OECD Forum on Tax Administration (FTA) has published a report titled “Tax Administration 3.0: The Digital Transformation of Tax Administration”. This discussion paper sets out a different model of tax administration, enabled and in fact called for, as a result of increasing digitalisation of the economy and of society in general. Moreover, it takes clear direction for tax administrations to become real time data driven and able to automate validation of taxpayers. It is important for taxpayers to understand the paradigm shift and already anticipate that when starting an ERP transformation.
Join our online seminar on Amendments to the Double Tax Treaty between Switzerland & Ukraine on 4 December
Register and join our online seminar on Friday 4 December 2020, 9am CET to discuss the entry into force of the Protocol to Tax Treaty between Switzerland and Ukraine on avoidance of double taxation with respect to taxes on income and capital, and amendments provided by it.
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.