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The Evolution of Tax Enforcement in Switzerland

The Evolution of Tax Enforcement in Switzerland

As in the rest of Europe, Swiss tax authorities have ramped up examinations of cross border transactions of Swiss residents and cooperation with tax authorities in other countries. Examinations of Swiss residents focus on the abuse of offshore structures and increases in the number of tax examinations and aggressiveness of tax authorities. Regarding Swiss holding companies owned by nonresidents, Switzerland now has an active exchange of information program that provides administrative assistance within the framework of the more than 100 double tax treaties. Thierry Boitelle, the Founding Member of Boitelle Tax Sàrl, in Geneva, and his colleagues Sarah Meriguet and Marine Antunes, Senior Associates at the firm, explain all.

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Insights Vol. 4 No. 11: Updates & Other Tidbits

Insights Vol. 4 No. 11: Updates & Other Tidbits

This month, Sheryl Shah and Nina Krauthamer look briefly at two I.R.S. actions: (i) the roll out of a long-awaited passport denial program and (ii) the end of favorable rulings on certain worthless stock deductions and spinoffs.

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Spontaneous Exchange of Tax Rulings – The Swiss Angle

Spontaneous Exchange of Tax Rulings – The Swiss Angle

Most – but not all – global tax advisers know that the tax planning universe has changed.  The few holdouts hoping that the old ways may yet be available were disappointed, again, when Switzerland announced procedures for the spontaneous exchange of tax rulings.  Rulings issued on and after January 1, 2010, will be exchanged beginning January 1, 2018.  Michael Fischer and Marc Buchmann of Attorneys Fischer Ramp Partner AG, Zurich, explain the new procedures and how taxpayers may take steps to stop the spontaneous exchange of existing rulings.

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