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Switzerland, by some referred to as “crypto nation”, already has non-profit foundations to house hundreds of millions of dollars crowdfunded by blockchain projects and the crypto foundations continue to thrive in Switzerland.
In December 2021, the Swiss Federal Tax Administration as well as the Association of Swiss Tax Administrations published their updated workpapers and guidelines on the taxation of crypto coins and projects. The new guidelines are based on real life cases that have been presented to and discussed with the authorities up to December 2020.
On 13 January 2022 the Swiss government has published the framework on how OECD’s Pillar 1 and 2 shall be implemented into national law.
New webinar date - Practical implications on the Pillar 1 & 2 policy solutions developed by the OECD
The much anticipated, updated model rules relating to Pillar 2 have now been published by the OECD on Monday, 20 December. With this in mind, we are excited to announce that our Pillar 1 and Pillar 2 webinar will take place on Wednesday, 12 January from 16:00-17:30.
On 20 December 2021, the G20/OECD Inclusive Framework on BEPS ("inclusive framework") published Tax Challenges Arising from the Digitalisation of the Economy Global Anti-Base Erosion Model Rules (Pillar Two) ("model rules"). This follows on from the Statement on a Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy, agreed by more than 135 of its members on 8 October 2021.
Since 2017, the 141 member countries of the inclusive framework have developed a "two-pillar" approach to address the tax challenges arising from the digitalization of the economy: addressing nexus and profit allocation challenges ("Pillar One") and global minimum tax rules ("Pillar Two").
The long-awaited model rules provide more clarity on the future of a global minimum tax rate. Although the model rules have now been published and confirm the key parameters, further clarification on certain aspects is still required. Additional details shall be provided in a commentary that is expected to be published by the OECD by the end of January 2022.
OECD Inclusive Framework reaches agreement on taxing the digitalized economy and a global minimum rate
On October 8, 2021 the OECD/G20 Inclusive Framework (“IF”) on base erosion and profit shifting (BEPS) issued a statement and an implementation plan (together, “the statement”) agreed by 136 of the 140 members of the IF outlining the political agreement with respect to the two pillar approach to address the tax challenges of the digitalization of the economy. Pillar One, Amount A, would reallocate profits of the largest and most profitable multinational enterprises (MNEs) to market jurisdictions; Pillar Two would impose a minimum tax on MNEs with gross revenues in excess of EUR 750 million and would require certain jurisdictions to agree to a subject to tax rule (STTR) in their treaties. A preliminary agreement had previously been announced in July. The two-pillar solution will be delivered to the G20 Finance Ministers meeting in Washington on October 13, then to the G20 Leaders’ Summit in Rome at the end of the month.
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.