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UPDATE STATUS
ABOUT THE AUTHOR
INTRODUCTION
FORMS OF DOING BUSINESS
Main Forms of Doing Business with a Legal Presence
Main Forms of Doing Business
FORMATION
Main Formation Requirements
Tax Consequence of Contributions
CORPORATE RESIDENCE
Corporate Tax Residence
PERMANENT ESTABLISHMENTS
Foreign PE of a Domestic Entity
Domestic PE of a Foreign Entity
PE Force of Attraction Principle
Branch Profit (Deemed) Remittance Tax
TAX BASE
Tax Base for Resident Entities
Treatment of Foreign Profits / Losses
Tax Consolidation / Group Treatment
Tax Base for Non-Resident Entities
Source Rules with Respect to Income Derived by Non-Residents
Qualification of Specific Income Categories for Tax Purposes
DETERMINATION OF TAXABLE INCOME
Main Rules Governing the Determination of Taxable Income
Main Differences between Commercial and Tax Accounting
Depreciation and Amortization
Reserves and Provisions
Deduction of Cross-Border Payments and Non-Deductible Expenses
Taxation of Foreign Source Income
LOSSES
TAX RATES
Residents
Corporate Income Tax
Calculation of Effective Corporate Income Tax
Other Taxes
Non-Residents
Corporate/Profit Taxes
Withholding Taxes
Exit Strategies
FOREIGN TAX CREDITS
INCENTIVES AND SPECIAL REGIMES
Holding Regimes
Intellectual Property Management Regimes
Specific Regimes
Domiciliary Company
Mixed Company
Other Regimes
Incentives
BUSINESS TRANSFORMATION AND RE-ORGANIZATION
Acquisition Strategies
Re-organizations
Change of Foreign Ownership in Swiss Legal Entities
Tax Consequence of Business Emigration, Corporate Inversions and the Cessation of Business
Transfer Abroad
Liquidation
VAT ON INTERNATIONAL TRANSACTIONS
Taxable Person
Object of Taxation
Import Tax
Acquisition Tax
Input VAT Deduction
Refund of VAT to Non-Residents
BASE PROTECTION AND ANTI-AVOIDANCE MEASURES
GAAR and General Anti-Avoidance Measures
General Rules
Inbound Payments (Switzerland as Receiving State)
Outbound Payments (Switzerland as Source State)
Thin-capitalization and other Restrictions to Interest Deduction
Overview
Calculation of Maximum Allowable Debt
Interest Deduction Strategies
CFC and Similar Regimes
Transfer Pricing
Other Anti-Avoidance Rules
TAX MANAGEMENT AND COMPLIANCE
Books and Records
Type of Assessment
Calendar of Important Compliance Events
Tax Audits
Audit Process
Statute of Limitations
Interest and Penalties
Interest Compensation for Overpayment of Tax
Appeal Procedures
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