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Direct Tax
The ruling excludes vacation and business development days from service PE calculations and confirms virtual services from abroad don’t count, potentially reshaping compliance for multinationals
February 3, 2026
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  • The change of status from privileged to ordinary taxation can already be envisaged before a revised version of the Corporate Tax Reform III (CTR III) enters into force. Fabian Duss and Marc Dietschi of ADB Altorfer Duss & Beilstein explore this possibility and outline why it could prove beneficial for businesses.
  • The Federal Administrative Court recently rendered its judgment in a case that might cause substantial headaches to companies supplying goods to Switzerland. Laurent Lattmann and Désirée Högger of Tax Partner AG – Taxand Switzerland explain the relevant aspects of this case and the potential fallout if this judgment is upheld by the Federal Supreme Court.
  • Swiss taxpayers will gain some welcome tax repayments from the government after amendments to the Federal Withholding Tax Act (WHTA) entered into force. Olivier Eichenberger of KPMG Switzerland discusses the changes.

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