Our latest research and insights: Tax

OECD Financial Transactions Transfer Pricing Discussion Draft, Swiss Market Observations

OECD Financial Transactions Transfer Pricing Discussion Draft, Swiss Market Observations

Earlier this week the OECD released a non-consensus discussion draft (the Draft) on the transfer pricing aspects of loans, cash pooling, guarantees, hedging transactions and captive insurance structures. This blog provides our initial reactions to the first three of these areas.

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EU: CJEU issues positive decision for foreign investment funds

EU: CJEU issues positive decision for foreign investment funds

On 21 June 2018, the Court of Justice of the European Union (CJEU) issued its judgment in Fidelity Funds (C-480/16). The underlying question of the case was whether it is in accordance with the free movement of capital that non-resident investment funds are subject to withholding tax on dividends received from their Danish portfolio investments while resident investment funds are exempted from withholding tax on such dividend payments.

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Liechtenstein signs Double Taxation Agreement with Jersey

Liechtenstein signs Double Taxation Agreement with Jersey

On 8 June 2018 the Government of the Principality of Liechtenstein issued a press release stating that Liechtenstein has signed a Double Taxation Agreement (DTA) with Jersey. The DTA between Liechtenstein and Jersey shall in particular grant treaty access to asset structures, investment funds, pension funds and charitable organisations.

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What happens when the taxman gets superpowers?

What happens when the taxman gets superpowers?

Digitalisation meets tax authority: in a new white paper we explain why the corporate world should be preparing now for the imminent digitalisation of tax authorities. Companies will have to make extra efforts to get their tax capabilities quickly on the same data-driven level at which the authorities will be operating soon.

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Comparison of Tax Proposal 17 measures between Federal Council dispatch and Council of States

Comparison of Tax Proposal 17 measures between Federal Council dispatch and Council of States

On 7 June 2018, the Council of States discussed details about the Tax Proposal 17 measures, confirming the proposed changes of the WAK-S. Recently, the WAK-S had unanimously agreed on an overall concept which differs in several points from the dispatch on the draft law bill published by the Federal Council on 21 March 2018.

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CJEU judgment: Transactions not concluded at arm's length may be in line with EU law

CJEU judgment: Transactions not concluded at arm's length may be in line with EU law

On 31 May 2018, the Court of Justice of the European Union (CJEU) issued its judgment in Hornbach-Baumarkt (C-382/16). The case refers to German transfer pricing rules applying to transactions with foreign related parties and which do not provide the possibility for taxpayers to prove the existence of commercial reasons in case they conclude transactions not at arm's length terms.

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Paying Taxes 2018

Paying Taxes 2018

Now in its 12th edition, Paying Taxes is a unique report from PwC and the World Bank Group which uses a medium-sized domestic case study company to measure and assess the ease of paying taxes across 190 economies. This year we explore how the digital revolution is transforming almost every aspect of paying taxes.

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Conditions for Liechtenstein Foundations, Establishments and Trust Enterprises to apply double taxation agreement between Switzerland and Liechtenstein

Conditions for Liechtenstein Foundations, Establishments and Trust Enterprises to apply double taxation agreement between Switzerland and Liechtenstein

The double taxation agreement between Switzerland and Liechtenstein (DTA CH-LI ) is applicable since 1 January 2017. To benefit from the agreement, an entity or individual has to be resident in one or both of the contracting states. The term “resident” requires closer inspection when used in connection with a Foundation (Stiftung), Establishment (Anstalt) or Trust Enterprise (Trust reg.) according to Liechtenstein law.

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Liechtenstein has signed an additional DTA with Monaco

Liechtenstein has signed an additional DTA with Monaco

On 29 June 2017 the Government of the Principality of Liechtenstein issued a press release stating that Liechtenstein has signed an additional Double Taxation Agreement (DTA) with Monaco. The DTA between Liechtenstein and Monaco is intended to increase the legal certainty for investors and strengthen the close cooperation between the two countries.

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