Corporate Tax in Tax and Legal blog
Why obtaining Transfer Pricing certainty also becomes important for Pillar II?
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.
Deloitte Switzerland's Tax & Legal practice strengthens its capabilities with Thomas Hug joining as Partner
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.
Join our OECD Pillar Two/GloBE Tax Accounting seminar in Zurich, 20 – 22 November 2023
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.
CBAM: are you ready to comply?
1. What is CBAM?
The Carbon Border Adjustment Mechanism (CBAM) is a regulation pushed by the EU in the context of the EU Green Deal.
Under CBAM, Importers into the EU must pay a financial adjustment for the emissions released during the production of certain carbon-intensive goods in third countries.
The goal of the legislation is to mitigate the risk of carbon leakage and ensure the effectiveness of EU climate measures.
Is your company following the current tax transformation trends?
Through a survey of 300 senior tax and finance leaders across a variety of regions and industries, Deloitte has identified certain tax transformation trends impacting the tax and finance teams of large multi-national enterprises.
First of all, data and cost management are still priorities for heads of tax. However, there is now a clear focus on tax-related systems integrations and the adaptations needed to comply with the changing tax regulatory landscape, driven, in particular, by the OECD Pillar 2 regime.
Also, as technology is evolving quickly and becomes a “must have”, companies are exploring different strategies to access technology capabilities, including through outsourcing,
Finally, technology is also a key capability sought in new tax staff hires, where there is a race for the “unicorn” profiles, combining industry knowledge, tax savviness and data/IT expertise.
Update of the Geneva practice on the taxation of management incentive plans
On July 3, 2023, the Geneva tax authorities (GTA) published on their website an amendment to the way in which they tax management incentive plans.
The new amendment increases the scope for beneficiaries of management incentive plans to receive benefits in a more tax efficient way.
Global Minimum Tax: Swiss voters pave the way for implementation in 2024
In the popular vote on 18 June 2023, Swiss voters approved the most extensive change to the Swiss corporate tax system in over a century with a wide majority. With the amendment of the Swiss constitution the Swiss voters have paved the way for the Swiss legislator to introduce the global minimum tax (also referred to as “Pillar II”) in Switzerland.
Pillar II introduces an additional layer of taxation (tax law) to Swiss constituent entities of multinational enterprises in scope of the rules and introduces a corporate group taxation system in Switzerland with a mandatory tax of 15% that is determined under a new tax basis (“GloBE”).
The magnitude of change is significant and will redefine the Swiss corporate tax environment in the years to come.
Potential abolishment of the Geneva Municipal Business Tax and increase of the income tax rate
Created at the end of the 18th century, the Municipal Business Tax (“MBT”) (Taxe Professionnelle Communale) is only levied by the municipalities of the canton of Geneva and covers the gainful commercial activity of legal entities and individuals carried on in the canton.
Switzerland prepares to vote on global minimum tax
As countries across the world continue with their efforts to implement the OECD’s global minimum tax (Pillar Two, or GloBE Rules) into domestic law, we see Switzerland is continuing to lay the groundwork for the nation to adopt the rules.
The Swiss implementation journey began in June 2022 with the release of their roadmap to adopt the GloBE Rules. The roadmap intends to apply the income inclusion rule (IIR) and qualified domestic minimum top-up tax (Q/DMTT) as of 1 January 2024.
A referendum is scheduled on 18 June 2023, providing the federal government with the authority to continue with the implementation. As Switzerland continues to move forward, it is crucial for in-scope groups located in Switzerland to understand the financial reporting, disclosure and compliance requirements that are on the horizon. This leaves companies with the short time frame to assess the implications of the rules on the organizations.