Financial Services Tax in Tax and Legal blog
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.
Join our Financial Services Tax webinar relating to high interest rates, withholding tax reclaims, Pillar 2 and VAT updates on 31 May 2023 at 8.30 am CET
We would like to invite you to our upcoming webinar on high interest rates, withholding tax reclaims, Pillar 2 and VAT updates on Wednesday 31 May 2023 at 08.30am.
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.
Is the banking sector ready for tax technology?
The use of tax technology has been increasing over the last decade, as organizations seek to gain efficiencies and deliver more value from their tax data. However, this has developed more slowly in the banking sector than other industries. Specific challenges faced by banks can explain slower tax technology adoption, such as complex system infrastructure, special tax treatment applicable to the banking industry, dispersed tax processes responsibilities and higher data security restrictions. Given the current external and internal pressure on tax functions to increase efficiency, there is no better time to develop a tax technology agenda supported by strong business cases. Adopting new software solutions to improve tax processes is not necessarily a synonym of large project costs and disruption. From taking a step-by-step approach to bigger transformation plans there is a breadth of strategies to enable tax functions within the banking sector to initiate a tax technology journey.
Same but different: a comparison of the OECD CARF and the EU DAC8 proposal
The emergence and rise of alternative methods of payment and investments such as crypto-assets and e-money has heightened global regulators’ interest. This has prompted the publication of various proposals and frameworks to ensure that the recent gains on tax transparency do not get lost and due taxes are paid.
Deloitte Finance Day 2023 - The colours of finance - design your future capability - 1 June 2023 in Zurich
Join our OECD Pillar II webinar on 15 February 2023, 4.00pm
The implementation of the Global Minimum Tax (“OECD Pillar II”) experienced a significant push towards reality in late December 2022, which included:
- The European Union adopting the directive requiring members to transpose it into domestic legislation
- Switzerland completing the parliamentary process on its change of constitution
- The OECD`s publishing a number of papers to guide the GloBE implementation (in particular: safe harbours, information return and tax certainty)
To navigate these developments we are organising a keynote webinar on Wednesday 15, February 2023 from 4.00 to 5.30pm to discuss these and other topics.
South Korea: First Country to pass the domestic Global Minimum Tax legislation
On 23 December 2022, the Korean National Assembly officially passed the 2022 Tax Revision Bill originally announced by the Ministry of Economy and Finance back in July 2022.
This is a pivotal moment in the advancement of the global minimum tax “Pillar Two” as South Korea is the first country to codify the GloBE Rules into domestic legislation. The newly passed law provides that a global minimum tax will be introduced from fiscal years beginning on or after 1 January 2024.
Proposed changes to the Qualified Intermediary agreement introduce burdensome requirements to collect US TINs
This blog is the second of a two-part series and discusses the due diligence challenge linked to a Qualified Intermediary (QI) holding Publicly Traded Partnership (PTP) interests in custody for non-US investors as of 1 January 2023 when the new PTP withholding regulations come into force: the collection of non-US investors’ US TINs for purposes of §1446(a) and §1446(f).
You can access here our first blog in this series which addressed QI difficulties in complying with electronic reporting obligations via FIRE due to new US TIN requirements introduced for identity verification purposes.
Deloitte's Tax practice strengthens its capabilities for financial services, banking and insurance clients with two new key partners
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.