Editorial

International Tax Review is part of Legal Benchmarking Limited, 4 Bouverie Street, London, EC4Y 8AX

Copyright © Legal Benchmarking Limited and its affiliated companies 2025

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Editorial

Switzerland is often discussed when the ethics of international tax competition are questioned, but recent events prove the country's willingness to adapt to the latest international standards.

However, as the landlocked country tries to adapt its tax system to meet its international commitments, the goal appears to be in direct conflict with its intentions to remain attractive to foreign investors. As Tax Partner AG – Taxand Switzerland's article indicates, the country is succeeding in both its objectives, however.

Burckhardt's article also touches on the country's ability to adapt to international influences while maintaining its reputation among big businesses as the place to locate key operations. The article looks at what the Swiss financial centre offers and how proposals to amend the Swiss Withholding Tax Ordinance will strengthen the financing activities of groups.

However, the onus for change is not always the responsibility of the government. ADB Altorfer Duss & Beilstein's article discusses how companies can voluntarily abandon a privileged tax status and move to ordinary taxation before a preferential regime is abolished.

Meanwhile, this guide also summarises the concept of substance in relation to tax matters. The term "substance" can have very different meanings and Deloitte discusses how it is of fundamental importance for the purposes of a substance-based analysis to avoid disputes – particularly those involving cross-border operations.

Laurent Lattmann & Désirée Högger of Tax Partner AG – Taxand Switzerland believe cross-border issues for companies are unlikely to go away soon. In their article, they discuss a recent VAT judgment issued by the Federal Administrative that will impact companies supplying goods to Switzerland.

However, it's not all bad news for companies. Many Swiss taxpayers, who were charged heavy amounts of late interest in relation to dividend payments, will benefit from a total repayment of CHF 600 million ($596 million) from the Swiss Confederation, writes Olivier Eichenberger of KPMG Switzerland.

We hope the fifth edition of this Switzerland guide provides useful insight as taxpayers seek to navigate a constantly-evolving landscape.

Anjana Haines

Editor, International Tax Review

more across site & bottom lb ros

More from across our site

It is understood that the US has vowed to oppose any outcome from talks taking place at the UN
It’s the second year in a row that RSM’s tax business has posted fee income growth above 10%
Recent guidance from the Indian tax authorities should provide confidence for investors, says Sanjay Sanghvi of Khaitan & Co
Grant Wardell-Johnson also suggests there could be solutions to the friction between the US and the OECD when it comes to pillar two
The president had so far avoided announcing tariffs on the US’s neighbours despite previous threats
The firm brought in three managing directors from EY and Deloitte in Europe; in other news, KPMG’s bid to practise law in US was delayed
One expert argues the ERS would be unlikely to improve taxpayers’ experience unless it comes with additional funding to hire more agents and staff
From pillar two and amount B to Apple’s headline EU Commission dispute, Martin Bonner and Yiwen Ping of Kreston Global argue that 2024’s key TP developments will inform 2025
Holland & Knight, Nelson Mullins and McCarter & English made the joint-most tax partner hires in the US last year, according to annual ITR Talent Tracker data
Despite a three-year-high in tax revenues generated from settling TP cases, HMRC reported a sharp fall in resolved MAP disputes
Gift this article