Stefano Cavargna
Paolo Cavargna
Stéphane Joris
Interest rates allowed for tax purposes in 2023
Publication by the Federal Tax Administration (FTA) of the annual circular letters on the interest rates allowed for tax purposes in 2023 on advances or loans made between a company and its shareholders or related parties. When a company grants advances or loans without interest or for an insufficient interest to its shareholders or related […]
Communication from AFC of Decembre 10, 2019 (FF 2019 7777)
This request is based on Art. 27 of the Convention of 9 March 1976 between the Swiss Confederation and the Italian Republic for the Avoidance of Double Taxation with Respect to Taxes on Income and on Capital. Information are related to natural persons; whose names are unknown and who fulfill all of the following criteria during […]
Federal Act on Implementation of Recommendations of the Global Forum will enter into force on November 1, 2019
On June 21, 2019, the Swiss Parliament adopted the Federal Act on the Implementation of Recommendations of the Global Forum on Transparency and Exchange of Information for Tax Purposes. This Act implements the Global Forum’s recommendations made to Switzerland in the Phase 2 report. On September 27, 2019, the Federal Council decided that the Federal […]
Working document of the Swiss Federal Tax Administration in relation to the taxation of cryptocurrencies and the initial coin/token offerings
The Swiss Federal Tax Administration published a working document related to the cryptocurrencies and the initial coin/token offerings (ICO/ITO) with respect to wealth tax, income tax and profit tax, Swiss withholding tax and stamp duty.
Judgement of the Federal Court of July 26 2019 regarding administrative assistance in tax matters
In a judgement dated July 26th 2019 (2C_653 / 2018), the Federal Court (FC) approved the transmission of data concerning approximately 40’000 UBS accounts to the French tax authorities. Essentially, the FC considered that the French request does not constitute a fishing expedition and that the French authorities respect the principle of specialty. As a […]
Notification from the FTA of 25 June 2019 (FF 2019 4211)
The Ministry of Finance of Israel requests the FTA for administrative assistance. This request is based on the Multilateral Convention on Mutual Administrative Assistance in Tax Matters (entered into force on January 1st, 2017 as regards Switzerland) and not on the double tax agreement concluded between Switzerland and Israel since this agreement does not include […]
Notification from the FTA of 12 June 2019 (FF 2019 3774)
The Ministry of Finance of Israel requests the FTA for administrative assistance. This request is based on the Multilateral Convention on Mutual Administrative Assistance (entered into force on January 1st, 2017 as regards Switzerland) and not on the double tax agreement concluded between Switzerland and Israel since this agreement does not include the OECD standard […]