Konzerne betrauen häufig eine Konzerngesellschaft mit dem Management des Cash für den ganzen Konzern. Mit seinem Urteil vom 16. Oktober 2014 konnte das Bundesgericht zu wesentlichen rechtlichen Fragen einer Zero Balancing Cash Pooling-Struktur Stellung nehmen.
Foreign companies performing supplies of goods in Switzerland will likely need to re-evaluate their Swiss VAT obligations. The rules on the VAT liability of foreign companies will change as of 1 January 2015. For some of them, the reverse-charge mechanism will no longer apply and a VAT registration might become mandatory.
On 30 November 2014, Swiss voters decided to keep the tax regime of expenditure-based taxation. This means that the taxation based on cost of living remains intact for persons with residence in Switzerland and also for those who plan to relocate to Switzerland in the future.
Not just since the BEPS project by the OECD, tax transparency has been the new buzzword. However, the recent examples of “Luxembourg Leaks” and state aid investigations by the EU have proven that tax transparency is definitively here to stay and to become even more serious.
Switzerland signs new treaty with Cyprus and improves its treaty network. In the new DTT with Cyprus, the residual withholding tax on dividends from the minimum equity holdings of 10% as well as on interests and royalties could be reduced to nil and is therefore more favorable than the EU tax savings agreement.
Based on the latest Swiss CTR III law, KPMG Switzerland has compiled a digital brochure which compares the detailed regulations of the legislative draft with the current Swiss corporate tax legislation.