FOREIGN OWNERS IN CANADA MUST REGISTER TO PAY A NEW TAX ON “UNDERUSED” PROPERTY   Most foreign individuals, companies and other entities that own residential properties in Canada must now file a return even if no tax is due. This is one of the requirements of the new “Underused Housing Tax Act” (“UHT”) effective for the...Read More

Swiss safe haven intercompany interest rates for 2023 announced by SFTA   The Swiss Federal Tax Administration (#SFTA) has published the safe haven interest rates applicable for the year 2023 in its updated annual circular letters No. 203 and 204. The rates are for loans in #Swiss #Francs (CHF) and in foreign #currencies to and...Read More

Large Swiss companies will have to submit climate reports from 2024   A “green” breakthrough for large Swiss companies: starting from 2024 they will have to submit climate impact reports. The innovation is contained in the implementing ordinance adopted by the Federal Council in late 2022. The ordinance requires large Swiss companies to implement in...Read More

ECOFIN PUTS RUSSIA AND BVI ON BLACKLIST   The blacklist of tax havens continues to grow. At its meeting on 14 February, the Economic and Financial Council of the European Union (also known as Ecofin) added Russia, the British Virgin Islands, Costa Rica and the Marshall Islands to the list of non-cooperative jurisdictions for tax...Read More

ATAD 3 AND SWISS HOLDING COMPANIES While the European Union’s implementation of ATAD 3 will not directly affect Swiss entities, it might as a matter of fact make Swiss holding companies more attractive for international corporations and wealthy individuals. STATUS QUO The latest amendments to the European Commission’s draft directive for preventing the misuse of...Read More

WITHHOLDING TAX: AMENDMENTS TO THE NOTIFICATION PROCEDURE Good news for Swiss groups and holdings with subsidiaries in Switzerland regarding withholding tax. As of January 1, 2023, changes related to the Ordinance of May 4, 2022 (“RU 2022 307”) on the notification procedure within a group for withholding tax purposes will take effect. The notification procedure...Read More

INDIVIDUAL TAXATION IN SWITZERLAND: CONSULTATION BEGINS On Dec. 2, the Federal Council launched the consultation procedure on the reform that aims to introduce an “individual taxation” of every taxpayer, even if married. The consultation will end on March 16, 2023. The legislative process was initiated by the Federal Council as a counterproposal to the popular...Read More

TAX RESIDENCY IN THE EMIRATES: A FIRST LAW TO PROVIDE CLARITY For the first time, tax residency in the United Arab Emirates has being regulated at a legal level. Thanks to “Cabinet Resolution No. 85” of 2022, the local government has brought clarity by enacting a new domestic regulation that aims to clarify of when...Read More

Hong Kong foreign-sourced income will soon be taxed 2023 could represent a watershed for Hong Kong’s corporate taxation. The Inland Revenue Amendment Bill 2022 (about Taxation on Specified Foreign-sourced Income), gazetted on 28 October 2002, is now under scrutiny by the Legislative Council of Hong Kong and is expected to come into force in 2023,...Read More

The new frontier of transparency in the USA – Trusts in the context of FinCEN’s Final Rule Regardless the steps traditionally taken by the United States of America in order to meet the highest international standards in terms of safeguards designed to prevent the flow of illicit money and contrast illicit activities, including money laundering,...Read More