March 20, 2020

Swiss Corporate Tax Reform: T.R.A.F. in a Nutshell

March 20, 2020/ Ruchelman P.L.L.C.

As a result of a favorable vote last year, T.R.A.F. – the tax reform in Switzerland – came into effect on January 1, 2020. T.R.A.F. was crafted to generate additional revenue for cantons, enhance old age pensions and survivors insurance funding, and reform corporate tax rules. Peter von Berg of Blum&Grob Attorneys at Law in Zurich, Switzerland, identifies the major changes for companies and individuals and provides examples of the effects on various entities.

June 27, 2017

New Proposal for Swiss Corporate Tax Reform

June 27, 2017/ Ruchelman P.L.L.C.

Through the first ten days of February, Swiss tax advisers were contemplating life after the adoption of the Corporate Tax Reform III (“C.T.R. III”). Then, the bottom dropped out from under their feet as Swiss voters defeated the tax reform package by an almost 60-40 majority. Now, a Steering Committee representing the cantons and Swiss Federation has issued T.P. 17, recommending a modified version of corporate tax reform. Peter von Burg and Dr. Natalie Peter of Staiger Attorneys, Zurich, compare the provisions in T.P. 17 with those in C.T.R. III.

February 21, 2017

Swiss Corporate Tax Reform Postponed

February 21, 2017/ Ruchelman P.L.L.C.

Through the first ten days of February, Swiss tax advisers were contemplating life after the adoption of the Corporate Tax Reform III (“C.T.R. III”). Then, the bottom dropped out from under their feet as Swiss voters defeated the tax reform package by an almost 60-40 majority. Peter von Burg and Dr. Natalie Peter of Staiger Attorneys at Law in Zurich explain the benefits that were contemplated under C.T.R. III and ponder about what will be adopted in its place. Switzerland must act promptly to cobble together a replacement package that will appease opponents of C.T.R. III and meet the deadline under its agreement with the E.U. for eliminating existing special benefits allowed to base companies. How much of C.T.R. III can be salvaged?

January 15, 2016

Insights Vol. 3 No. 1: Updates & Other Tidbits

January 15, 2016/ Web Admin

This month, Insights discusses recent events including a Beanie Baby billionaire’s light sentence; a tax reform report by the European Parliament addressing tax rulings, a common consolidated corporate tax base, a crackdown on tax havens, whistle-blower protection, public access to country-by-country (CbC) reports, and a lower threshold to approve E.U. tax legislation; a House Ways and Means Committee action in regard to B.E.P.S., E.U. investigations on State Aid, patent box regimes, and inversions; identity theft risk in I.R.S. proposed regulations regarding charitable deductions; and allowance of accounting non-conformity for foreign-based groups that do not adopt L.I.F.O. accounting when that method is adopted by a U.S. member.

December 15, 2015

Insights Vol. 2 No. 10: Updates & Other Tidbits

December 15, 2015/ Ruchelman P.L.L.C.

This month, "Updates & Tidbits" looks at two recent developments in the E.U. The first relates to findings of illegal State Aid in the form of private rulings given by Luxembourg and the Netherlands – Starbucks and Fiat plan to appeal. The second relates to double dipping of tax benefits when establishing I.P. box companies.

September 15, 2015

Final Stages of B.E.P.S. Implementation and its Effects

September 15, 2015/ Web Admin

As the conclusion of the O.E.C.D.’s B.E.P.S. Project draws ever nearer, Rusudan Shervashidze examines domestic implementation efforts in a number of foreign countries and the unanticipated tax ramifications for multinational enterprises. In their attempts to meet these requirements, countries are making some of the most significant changes to international taxation policy that we have seen in decades.

February 15, 2015

Proposed Legislation for Italian Patent Box Regime

February 15, 2015/ Web Admin

Currently. the O.E.C.D. and E.U. are finalizing new rules for the design of acceptable tax regimes for intangible property (“I.P.”) box companies – a tax benefit that is seen by the E.U. as a form of illegal state aid. Germany, France, Spain, and Italy are seen as the champions of the new regulations. However, Italy recently introduced its own I.P. tax incentive plan, known as a “patent box regime.” Stanley C. Ruchelman and Kenneth Lobo examine Italy’s incentive program, in light of the O.E.C.D. and E.U. attacks on such regimes.