Switzerland in International Tax Law
(Third Edition)
Authors: Xavier Oberson and Howard R. Hull

Summary

The past five years of Swiss international tax law have been marked by a significant shift towards EU and OECD compatibility. This is has led to an Agreement between Switzerland and EU Member States which introduces measures inter alia, equivalent to those found in the EC Savings Directive, Parent-Subsidiary Directive and the Interest and Royalties Directive. These have a significant effect on cross-border investments and are developed extensively in this edition.

The influence of the EU and OECD has also resulted in a clear move within the Swiss tax environment towards the adoption of internationally recognized transfer pricing methodologies. To this aim, Switzerland has phased out some of its safe harbour tax regimes granted previously to service companies and international sales companies.

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In addition, there have been significant changes regarding the approach taken to the international exchange of information and assistance in tax matters. On the other hand, EU and OECD involvement has also led to the understanding by the international community of some of the tax relief opportunities which remain available to companies in Switzerland.

Switzerland in International Tax Law is designed for practitioners wishing to acquire a working knowledge of the Swiss tax issues involved in international cross-border investment. Whether Switzerland is the source or the destination of income, both domestic and international laws are explained in detail. Due to Switzerland’s traditional role in international tax planning, particular attention has been paid to the special tax relief granted to Swiss resident individuals and corporations as well as the complex rules for the avoidance of treaty abuse.

Main Contents

  • Swiss Domestic Law
  • Swiss Treaty Law
  • International Allocation of Taxable Income
  • Double Taxation Relief
  • Anti-abuse Provisions
  • Transfer Pricing
  • Mutual Agreement Procedures
  • Exchange of Information
  • Swiss-EU Bilateral Agreements
The Authors

Xavier Oberson is Professor of Swiss and International Tax Law at the University of Geneva. His is a partner in the Gevena law firm Oberson & Partners and a Judge at the Federal Court of Appeal for Taxation. He is also a member of the IFA Permanent Scientific Committee. After being admitted to the Geneva Bar, he obtained a Doctorate of Law from Geneva University and an LLM from Harvard Law School where he also completed the International Tax Program.

Howard R. Hull is a Partner with Ernst & Young. He is responsible for the International Tax Practice in the Geneva area. After obtaining a degree in law from the University of Geneva, he qualified as a Certified Swiss Tax Consultant (expert fiscal diplômé). He lectures on International Tax issues at the Swiss Tax and Accountancy Academy. A prolific author of articles on Swiss and International taxation, he speaks regularly on matters of international tax law.
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