Oberson; Hull

Switzerland in International Tax Law

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. 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.