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Expert AnalysisSpecial Focus

Time of the essence – ITR’s Switzerland Guide 2023 launched

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ITR has partnered with leading Swiss tax specialists to consider the most pressing taxation issues facing the country.

2023 marks a critical moment in Swiss taxation. The country is forging ahead with the implementation of the OECD’s global minimum tax, while the tax authorities are also adjusting to the new reality of working from home and managing cross-border commuting. Another significant area in the jurisdiction, fintech and blockchain, is similarly demanding guidelines that keep pace with the rapid developments in the sector.

Deloitte Switzerland considers the benefits and risks as Switzerland pushes towards the implementation of the GloBE Rules into domestic law, with a referendum due on June 18 2023. If the referendum approves an amendment to the Swiss constitution, the government will press ahead with its plans, with a view towards the introduction of the rules from January 1 2024.

Adaptation to take account of developments is also a theme in the article from Tax Partner AG, which analyses Switzerland’s bilateral cross-border commuter agreements, with a special focus on working from home. The COVID pandemic has perhaps changed the nature of working from home for ever, with the authors identifying the issues relating to the taxation of employment income for commuters with employment in Switzerland but residency abroad.

MLL Legal explains the Swiss guidelines relating to the qualification and categorisation of block rewards of cryptocurrency consensus mechanisms in the country’s tax law. The recent developments are analysed as Switzerland establishes itself as one of the world's leading locations in the areas of distributed ledger/blockchain technology.

The authors from burckhardt note the increasing influence of Swiss administrative assistance in tax matters, which should be on the radar of companies with a group-related or a contractual link to Switzerland. Important information can be obtained by requesting administrative assistance from another state, usually based on a double taxation agreement.

Taxation in Switzerland is having to respond to developments in several areas, and these articles provide expert-level insight into how the country is addressing the challenges. Time is therefore of the essence for the tax authorities and taxpayers.

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