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Bulletin for International Taxation
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Issue No. 4/5 - 2015 of the Bulletin for International Taxation is now available online.

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Number 4/5 - 2015 contains the following:


President's Welcome

Porus F. Kaka

Meine Damen und Herren, dear IFA Colleagues, flushed with the success of the Mumbai Congress, it is my pleasure to present the 69th Congress of the International Fiscal Association (IFA) to be held in Basel from 30 August to 3 September 2015.


Switzerland in a Post-BEPS World

Robert Danon and Christoph Schelling

The authors, in this contribution, consider the implications of the OECD Base Erosion and Profit Shifting project, on Swiss corporate tax policy. While they generally support the BEPS project, the authors believe that its implementation should also take national tax policies differences into account.


Potential Effects of the OECD Base Erosion and Profit Shifting Initiative on Swiss Transfer Pricing Rules and Swiss Companies

Raoul Stocker

In this contribution, the author considers the implications of the Base Erosion and Profit Shifting initiative of the OECD with regard to Switzerland’s transfer pricing practice, Swiss companies and potential changes to Swiss tax law.


Swiss Tax Treaty Policy

Christoph Schelling

In this article, the author presents an overview of Swiss tax treaty policy and comments on recent developments in this area.


Transparency and Exchange of Information with Switzerland – The Possibilities and Overview of the Legal Framework

Urs Kapalle

In this article, the author examines the Swiss legal framework for exchange of information in tax matters.


Private Tax Rulings in Switzerland

Christoph Niederer and Martin Dubach

The authors, in this article, consider the private tax ruling system in Switzerland, together with the relevant aspects and implications of using the system.


The Taxation of Philanthropy in Switzerland: Current Status and Suggestions for Improvement

Xavier Oberson

In this contribution, the author describes the current rules with regard to the taxation of philanthropic activities in Switzerland and makes various suggestions for improvements to the current regime. In this respect, the developments in EU law with regard to cross-border giving are also taken into account.


Trusts and Taxation in Switzerland

Pierre Gillioz and Nicole Fragnière Meyer

The authors, in this article, examine the treatment of trusts and the taxation of settlors and beneficiaries resident in Switzerland. They also explore the advantages and disadvantages of modifying trust deeds before and after the settlors and/or the beneficiaries move to Switzerland and become Swiss taxpayers.


Practical Protection of the Fundamental Rights of Taxpayers

Robert Desax

In this article, the author examines selected practical aspects of the protection of the fundamental rights of taxpayers in Switzerland, together with the enforcement of these rights as well as obstacles that frequently arise in practice.

The Taxation of High-Net-Worth Individuals in Switzerland
Daniel Bader and Corinna Seiler
In this article, the authors provide an overview of the current Swiss tax regime for high-net-worth individuals (HNWIs) and of the important future developments on that matter.


Tax Incentives for Research and Development

Dieter Weber and Stephanie Eichenberger

In this article, the authors examine the Swiss rules aimed at encouraging research and development activities on the Swiss territory.


Relocation of a Company’s Business to Switzerland

Hans Koch, Nina Keller and Patrick Schmid

In this contribution, the authors examine the various direct and indirect tax implications for a company considering relocating either itself or its operations to Switzerland.


Tax Considerations for M&A Transactions and Restructurings in Switzerland

Barbara Brauchli Rohrer

This article details the principal tax considerations relevant for M&A transactions and restructurings in Switzerland. It explains the main reorganization schemes and their Swiss tax consequences, as well as the differences between asset deals and share deals from a Swiss tax point of view.


European Union

Neutrality and Territoriality – Competing or Converging Concepts in European Tax Law?

Wolfgang Schön

This article is based on the Klaus Vogel Lecture delivered on 24 October 2014 at the Vienna University of Economics and Business. It criticizes the increasing recognition of territorial taxing rights in the jurisprudence of the ECJ and pleads strongly both for a unilateral discrimination test and the revival of the concept of coherence.

European Union

Neutrality and Territoriality: Competing or Converging Concepts in EU Tax Law? - Comment

Heinz-Klaus Kroppen

This contribution comments on the Klaus Vogel Lecture given on 24 October 2014 at the New Campus of the WU Vienna and published in this issue of the Bulletin for International Taxation.


Public Discussion Draft on Interest Deductions Proposes Worldwide Interest Allocation Rules

Jan Vleggeert

This article examines the approach to tackle BEPS through the use of interest cost, which was presented in the OECD public discussion draft on interest deductions and other financial payments.