March 28, 2023

Tax Issues for Remote Workers and Their Swiss Employers

March 28, 2023/ Ruchelman P.L.L.C.

While COVID-19 had a profound effect on remote working in various countries, Switzerland has long experience with one form of remoter worker – the daily commuter across national borders. Surrounded on three sides by Italy, France, and Germany, Switzerland has negotiated several tax agreements with its neighbors that split the income tax pie and address social security coverage. Some agreements have national coverage, while others have local coverage affecting only the cantons and municipalities that straddle a specific international frontier. The stakes are high for a Swiss employer as the income tax rates and the social security charges can vary dramatically based on which country is allocated the right to tax. Thierry Boitelle, the founder of Boitelle Tax Sàrl, Geneva, and Sarah Meriguet, a Senior Tax Attorney at Boitelle Tax Sàrl, Geneva, explain all.

May 30, 2019

2020 Will Mark the End of an Era: Swiss Corporate Tax Reform Accepted

May 30, 2019/ Ruchelman P.L.L.C.

On May 19, 2019, Swiss Federal and Genevan cantonal voters accepted proposed corporate tax reforms by a large majority. As explained by Thierry Boitelle and Aliasghar Kanani of Bonnard Lawson Geneva, Switzerland will abolish its widely criticized cantonal special tax regimes and certain Federal regimes. At the same time, Switzerland and the cantons will introduce generally applicable reduced and attractive corporate income tax rates and several new special regimes, meeting current international standards and requirements. These changes will be effective as of 2020.

December 15, 2014

Foreign Correspondence: Notes from Abroad

December 15, 2014/ Web Admin

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HOLIDAY SHOPPING, CANADIAN RETAIL PRICES AND TRANSFER PRICING CONTROVERSY

By Michael Peggs

When people think of massive transfer pricing cases, the driver typically is the diversion of profits to a low-tax jurisdiction. But transfer pricing issues are now filtering down to the level of retail shoppers facing retail price disparity in adjacent jurisdictions. A typical case is the premium that Canadian purchasers generally pay over prices charged in the U.S. for comparable products.

Before the internet, it was customary for Canadians to receive flyers in the mail from U.S. grocery and department stores. The flyers offered bargains for the holidays. The internet now allows instant price comparisons and greater choice for Canadian consumers. Disregarding sub rosa impediments to competition that permeate many areas of the Canadian economy – think of cultural preferences – Canadians have complained loudly that retail prices are unfairly high when compared with exchange-adjusted U.S. prices. A typical example is print media where the premium for pricing the Canadian edition was not reduced over the period in which the Canadian dollar reached parity with its U.S. counterpart.

The Canadian government is now preparing to give the Competition Bureau new powers to persuade U.S. multinationals with Canadian retail operations to lower prices or to achieve retail price parity, as will be determined. One hopes that Industry Canada will intervene with the Canada Revenue Agency (“C.R.A.”) before drafting legislation, as an unintended consequence may be a new round of Canadian transfer pricing controversy.