Financial Services Tax in Tax and Legal blog

The global minimum tax roadmap: the fog begins to lift


In July 2021, the G7 and the G20 fuelled the OECD Inclusive Framework with the consensus on the introduction of a global minimum tax of 15%. The high pace of policy leads at the OECD continued well into 2022 with the GloBE Framework (Pillar I & II) published in October 2021, the GloBE Rules (Pillar II) in December 2021 and the extensive commentary providing further guidance (March 2022). While the initial momentum provided for ambitious implementation plans, different global crises and the complexity of the implementation work required have slightly stalled progress. However, recent developments have revitalised the domestic efforts to introduce GloBE Rules and various jurisdictions have published their plans recently – among others: Switzerland.

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Posted on 24/08/2022 | 0 Comments

New US Tax identification number requirements create unworkable situations for Qualified Intermediaries


The IRS has recently announced a number of changes related to identification requirements impacting Qualified Intermediaries (QIs). This blog is the first of a two-part series and describes how the current design of the Secure Access Account (SAA), and in particular the request to provide a US Tax identification number to validate the QI’s Responsible Officials identity, would impair the QIs’ capabilities to comply with their electronic reporting obligations through FIRE. The second part of this series, covering QI’s new due diligence challenges linked to their non-US account holders’ US Tax identification number requirement for 1446(a) and 1446(f) purposes, will follow in a separate blog.

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Posted on 13/07/2022 | 0 Comments

Join our Financial Services webinar relating to Operational Tax Risks on 22 June 2022 at 8.30 am CEST


We would like to invite you to our upcoming webinar on operational tax risk governance for the financial services industry on Wednesday 22 June 2022 at 08.30am.

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Posted on 9/06/2022 | 0 Comments

Tax authorities want a slice of the virtual pie: a new OECD Crypto-Asset Reporting Framework is on the horizon


Since the creation of the world’s first cryptocurrency by Satoshi Nakamoto in 2008, over 5’000 types of cryptocurrencies have emerged. The World Economic Forum estimates the total market cap of digital currencies at USD 1.7 trillion with over USD 90 billion of worth traded daily. In Switzerland, the use of blockchain technology and cryptocurrencies is also on the rise. Lugano recently launched “Plan B” making bitcoin legal tender and allowing citizens to pay for public services or taxes in Bitcoin, while Zug is known to many as the Swiss “Crypto Valley”.

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Posted on 7/04/2022 | 0 Comments

Seasons change and so does CRS: the OECD publishes public consultation document on amendments to the Common Reporting Standard


Nearly eight years after the adoption of the Common Reporting Standard (CRS), the Organisation for Economic Co-operation and Development (OECD) have done a bit of spring cleaning and published a public consultation document on a Crypto-Asset Reporting Framework (CARF) and proposed amendments to the CRS.

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Posted on 1/04/2022 | 0 Comments

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. 

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Posted on 4/01/2022 | 0 Comments

OECD GloBE update - Overview of the key parameters of the model rules


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.

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Posted on 22/12/2021 | 0 Comments

Financial Services Industry Tax Webinar on 14 December - tax and transfer pricing insights from Thibaut Urbain (SFTA)


We would like to invite you to our next Financial Services industry webinar on Tuesday, 14 December at 09.30am (CET) where we will discuss recent tax developments relevant to the Swiss FS industry. We are delighted to be joined by Thibaut Urbain, who is a transfer pricing expert with the Swiss Federal Tax Administration (SFTA)

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Posted on 29/11/2021 | 0 Comments

Fall breeze & autumn leaves: IRS released new draft Forms W-8

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Nature equipped our trees with the astonishing ability to drop their summer leaves when fall approaches to get ready for a new start of our everlasting seasonal cycle. The US Internal Revenue Service (IRS) this year is in sync with nature and is ready to replace various W-Forms for the next season. The IRS published new draft Forms W-8BEN, W-8BEN-E, W-8IMY and W-8ECI between late August and early September 2021, as well as the corresponding draft instructions.

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Posted on 16/09/2021 | 0 Comments

Deloitte is Swiss Tax Firm of the Year and Swiss Transfer Pricing Firm of the Year for the 9th time

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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.

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Posted on 14/09/2021 | 0 Comments