Switzerland Tax News
Corporate Tax Reform II – recent developments
ECJ: Previous Austrian rules discriminating dividends received from third countries are compatible with free movement of capital under grandfathering clause – details
Supreme Court held cantonal tax rates breach Federal Constitution
ECJ: German thin capitalization rules reclassifying interests paid to substantial shareholders in third States are not incompatible with EC law
Italian tax authorities interpret application of Art. 15 of EU-Swiss Agreement
Discussion draft on application and interpretation of non-discrimination article of OECD Model – details
Treaty between Netherlands and Switzerland – negotiations
Protocol to treaty between Switzerland and Spain enters into force - details
Memorandum of understanding concluded between Denmark and Switzerland
Revised Commentary on Article 7 of OECD Model released
Treaty between the United Kingdom and Switzerland – UK Court of Appeal decides on non-discrimination relief
Final Report on Improving the Resolution of Tax Treaty Disputes
Treaty between France and Switzerland – exchange of notes on dividends (Swiss-EU Agreement)
Company tax regimes of Swiss cantons exempting foreign profits incompatible state aid under EU-Switzerland Agreement
Protocol to treaty between Switzerland and Austria enters into force
Report on Attribution of Profits to PEs released
Treaty between France and Switzerland – exchange of notes on pension income published
Protocol to treaty between Finland and Switzerland enters into force
Protocol to treaty between Switzerland and Argentina signed
Protocol to treaty between Austria and Switzerland ratified
Protocol to treaty between Switzerland and Spain signed
Protocol between Finland and Switzerland presented to Finnish parliament
Protocol between Spain and Switzerland to be signed
Treaty between Peru and Switzerland – negotiations
Protocol to treaty between Finland and Switzerland signed
Protocol to treaty between Switzerland and Austria signed
UK
Protocol and MoU to treaty between Switzerland and UK initialled
Non-application of domestic withholding tax exemption to interest paid to Swiss finance branches
Netherlands clarifies application of (i) tax treaty with Switzerland; (ii) savings agreement between EU and Switzerland
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