Switzerland releases Q&A guidance on application of transfer pricing rules
On February 23, 2024, the Swiss Federal Tax Authorities (SFTA) published the Q&A guidance regarding the application of transfer pricing regulations in Switzerland. This guidance clarifies the application of the arm's-length principle and the
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Switzerland publishes safe harbor interest rate limits for 2024
On 31 January 2024, the Swiss Federal Tax Administration released two circulars concerning the safe harbor interest rate limits for shareholders and related party financing for 2024. The rates vary based on whether the financing is in Swiss francs
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Switzerland publishes transfer pricing guidelines
On 23 January 2024, the Swiss Federal Tax Administration published the updated Transfer Pricing Guide. The main provisions of the guide include: An overview of the arm's length principle and the consequences of non-compliance under Swiss law.
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Switzerland to implement pillar 2 global minimum tax in 2024
On 22 December 2023, the Swiss Federal Council published a release in which it confirmed enforcing the Pillar 2 global minimum tax in Switzerland from 1 January 2024. As previously reported, the Federal Council will gradually introduce the global
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Switzerland increases tax payment interest rates
On 11 September 2023, the Swiss Federal Tax Administration announced amended interest rates for late payment, refund, and advance tax payments. The announcement includes interest rates as follows: Interest rate for late payment and refund -
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Switzerland plans to extend loss carryforward time limit
The Switzerland Federal Council has recently made an announcement indicating that there is an ongoing parliamentary consideration of a proposal to extend the period for carrying forward losses from 7 years to 10 years. The primary objective of this
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Switzerland approves global minimum tax rules
Switzerland has achieved a major milestone in the adoption of the global minimum tax and the Base Erosion and Profit Shifting (BEPS) 2.0 Project. This important development occurred when a constitutional amendment was successfully passed through a
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Switzerland plans to introduce OECD BEPS Pillar Two minimum taxation rule
On 24 May 2023, the Swiss Federal Council made an announcement outlining the introduction of the OECD Pillar 2 global minimum tax. This implementation is now awaiting a referendum vote scheduled for 18 June 2023. If this is accepted, the Federal
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Switzerland publishes safe harbor interest rates for 2023
The Swiss Federal Tax Administration (SFTA) recently released Circular Letter No. 203 and Circular Letter No. 204 on 7 and 8 February 2023, respectively. These circulars provide safe harbor interest rates for intercompany loans and advances in Swiss
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Switzerland suspends tax information exchange arrangement with Russia
On 22 September 2022, the State Secretariat for International Finance (SIF) of Switzerland published a notification declaring the suspension of exchange of tax information with Russia. The temporary suspension applies to all types of tax information
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Switzerland: Public Consultation on Minimum Corporate Tax Rules
On 17 August 2022 Switzerland launched a consultation on an ordinance to legislate for important elements in the OECD’s global minimum corporate tax under Pillar 2 of the international tax measures. The draft legislation would introduce a Swiss
See MoreIMF Report Looks at the Economic Situation in Switzerland
On 6 April 2022 the IMF issued a report following discussions with Switzerland under Article IV of the IMF’s articles of agreement. The Swiss economy recovered in 2021 following the crisis caused by the pandemic, with growth reaching 3.7% and
See MoreSwitzerland publishes safe haven interest rates for 2022
The Swiss Federal Tax Administration (SFTA) has published two Circulars with safe-harbor interest rates 2022 for advances and intercompany loans in Swiss francs as well as in foreign currencies. Circular 195 of 27 January 2022 The minimum
See MoreSwitzerland: Review of international financial and tax developments in 2021
On 25 January 2022 Switzerland’s State Secretariat for International Financial Matters published its summary for 2021 entitled: Swiss financial and tax centre in 2021: more sustainable, more digital and in good shape despite the pandemic. The
See MoreSwitzerland: Implementation of OECD minimum tax rate by constitutional amendment
On 12 January 2022, the Federal Council decided to implement the minimum tax rate for certain companies agreed by the OECD and G20 member states by means of a constitutional amendment. Based on that decision, a temporary ordinance should
See MoreSwitzerland declares safe harbor interest rates
The Federal Tax Administration of Switzerland has published two separate circulars regarding safe harbor interest rate limits applicable to shareholder and related party loans in 2021. The rates may vary depend on whether the financing is in Swiss
See MoreSwitzerland: Review on international financial and tax matters of 2020
Switzerland’s Secretariat for International Finance (SIF) has published its annual review on international financial and tax matters for 2020. With respect to tax-related matters in particular, the review includes the following: Taxing
See MoreSwitzerland: Federal Council adopts dispatch on Federal Act on implementation of international tax agreements
On 4 November 2020, the Swiss Federal Council adopted the dispatch on the Federal Act on the implementation of international tax agreements. With this proposal, the Federal Council is adapting the existing law to the changes made to international
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