ITR Search | International Tax Review

Taxing non-resident employees

Ingo Heymanns and Andrew Chapman of PwC analyse a recent Federal Court of Switzerland ruling that provides clarification on the taxation of employment income for non-resident employees of an employer domiciled in Switzerland.

February 17 2012

Sustainability and defence of principal company structures

The concept of a principal company structure (PCS) is far from new, yet national tax regimes are increasingly targeting these structures for enhanced and aggressive scrutiny. While this increased scrutiny is not limited to Swiss-based PCSs, Carl Bellingham and John Lindstrom of PwC warn that tax authorities may focus on a Swiss-based PCS due to the sheer number of such structures in Switzerland.

February 17 2012

Switzerland as platform for IP and finance activities

For many years, Switzerland has been a successful jurisdiction for locating intellectual property (IP) and finance activities. One of the many reasons for its success resides in Switzerland’s capacity to provide a very competitive tax environment. Jean-Blaise Eckert and Heini Rüdisühli of Lenz & Staehelin’s Geneva and Zurich offices explain how taxpayers can take advantage of the tax benefits.

February 17 2012

Editorial: Still the place to be

Switzerland still remains an attractive place to do business, despite pressure from the EU to reform its cantonal corporate tax system.

February 17 2012

Tax transparency in the spotlight like never before

Companies around the world are beginning to understand the importance of transparency about their tax affairs and the reputational benefits of eschewing aggressive tax planning. They will have the opportunity to debate these crucial issues with administrators, activists and practitioners at International Tax Review's first Tax & Transparency Forum on May 2.

Salman Shaheen, February 17 2012

Exchange rate differences and foreign currency translation

Andreas Helbing and Fabian Duss of ADB Altorfer Duss & Beilstein outline the rules applying to bookkeeping in foreign currency and the translation of financial statements into local currency and look at how multinational groups are affected by a landmark court decision about the tax treatment of translation differences.

February 17 2012

Taxpayers and officials agree change to risk management needed to avoid disputes

Both taxpayers and officials need to change their approach to tax risk if they are to ensure greater compliance and reduce exposure to tax disputes, the Tax Council Policy Institute‘s annual symposium (TCPI) was told yesterday.

Jack Grocott, February 17 2012

When is tax planning reasonable in the context of a UK GAAR?

The UK is considering introducing a general anti-avoidance rule (GAAR) into its tax system. The key issue is when is tax planning to be considered acceptable and when is it to be considered "abusive"?

February 17 2012

How Nidwalden’s competitive licence box regime works

Nidwalden has created a licence box regime that offers tax relief for qualifying companies. Other cantons could follow its example, believes Harun Can of Schellenberg Wittmer.

February 17 2012

Pitfalls leading to creation of tax liability in Switzerland

To avoid creating a tax liability, taxpayers should be aware of the criteria to be taken into consideration when carrying out business activities in Switzerland, whether through use of a Swiss branch or a Swiss place of effective management, explains Rolf Wüthrich of burckhardt.

February 17 2012

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