Switzerland is often discussed when the ethics of
international tax competition are questioned, but recent events
prove the country's willingness to adapt to the latest
However, as the landlocked country tries to adapt its tax
system to meet its international commitments, the goal appears
to be in direct conflict with its intentions to remain
attractive to foreign investors. As Tax Partner AG –
Taxand Switzerland's article indicates, the country is
succeeding in both its objectives, however.
Burckhardt's article also touches on the country's ability
to adapt to international influences while maintaining its
reputation among big businesses as the place to locate key
operations. The article looks at what the Swiss financial
centre offers and how proposals to amend the Swiss Withholding
Tax Ordinance will strengthen the financing activities of
However, the onus for change is not always the
responsibility of the government. ADB Altorfer Duss &
Beilstein's article discusses how companies can voluntarily
abandon a privileged tax status and move to ordinary taxation
before a preferential regime is abolished.
Meanwhile, this guide also summarises the concept of
substance in relation to tax matters. The term "substance" can
have very different meanings and Deloitte discusses how it is
of fundamental importance for the purposes of a substance-based
analysis to avoid disputes – particularly those
involving cross-border operations.
Laurent Lattmann & Désirée Högger of
Tax Partner AG – Taxand Switzerland believe
cross-border issues for companies are unlikely to go away soon.
In their article, they discuss a recent VAT judgment issued by
the Federal Administrative that will impact companies supplying
goods to Switzerland.
However, it's not all bad news for companies. Many Swiss
taxpayers, who were charged heavy amounts of late interest in
relation to dividend payments, will benefit from a total
repayment of CHF 600 million ($596 million) from the Swiss
Confederation, writes Olivier Eichenberger of KPMG
We hope the fifth edition of this Switzerland guide provides
useful insight as taxpayers seek to navigate a
Editor, International Tax Review