Publications Transfer stamp tax for single investor funds Principle: Fund is exempt investor Domestic and foreign investment funds are generally considered exempt investors for the purposes of the (…) Liechtenstein financing structures in the new interest rate landscape The Liechtenstein tax administration has published the interest rates applicable to advances or loans to related parties for the 2023 (…) Tax-recognized interest rates for the year 2023 The Federal Tax Administration has published the interest rates applicable for the calendar year 2023 for advances or loans between (…) ATAD III: Preventing the use of EU-related shell companies ATAD III – EU Unshell Initiative On December 22, 2021, the EU Commission published a proposal for a directive to (…) Transfer stamp tax: Intermediation in Private Equity The transfer stamp tax on securities transactions The transfer stamp tax is levied on the purchase and sale of domestic (…) SFTA Practice Note: Limitation periods for the refund of withholding tax On 13 September 2022, the Swiss Federal Tax Administration (SFTA) published the applicable limitation periods for the assertion of a (…) Vicarious liquidation – Swiss withholding tax Court decision on the so-called vicarious liquidation in international relations In a much-noticed decision (BVGE A-4347/2019), the Federal Administrative Court (…) Implementation of minimum taxation in Switzerland Consultation on implementation opened On 11 March 2022, the Federal Council decided to implement the OECD/G20 project on the taxation (…) Tax risks on royalty payments from Germany Royalty payments in the tax authorities’ focus Beginning of January 2022, the German Federal Ministry of Finance (BMF) published two (…) Fund tax reporting in Switzerland / Liechtenstein Tax compliance for investment funds Foreign investment funds, which are distributed to Swiss and Liechtenstein investors must not only meet (…) Liechtenstein: Tightened practice on Thin Capitalization Tightened practice Since the 2017 tax period, interest on borrowed capital to the extent of the over-indebtedness of the Liechtenstein (…) Tax treatment of employee participation plans in Liechtenstein Employee shares for employees resident in Liechtenstein If an employer transfers employee shares to employees with tax residence in Liechtenstein (…) OECD-IF minimum taxation OECD Two-Pillar Approach on the Taxation of the Digitalisation of the Economy On July 1, 2021, the OECD / G20 (…)
