PORTFOLIO

Business Operations in Switzerland (Portfolio 986)

Tax Management Portfolio Business Operations in Switzerland, contains general information and tax rules that will enable a business to determine the best method of conducting its operations in Switzerland from both a tax and legal perspective.

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DESCRIPTION

The Portfolio analyzes the forms of doing business in Switzerland, and provides a detailed analysis of the tax rules applicable to corporations, individuals, partnerships, and other legal entities. In addition to a description of the income tax system, the Portfolio discusses capital and net wealth taxes, estate and inheritance taxes, stamp taxes, retail sales taxes and real estate taxes.

The Worksheets in the Portfolio include standardized articles of incorporation for a Swiss corporation. They also include combined federal, cantonal and municipal rate tables for both corporate and individual income taxes, as well as combined cantonal and municipal rate tables for individual income taxes. The Worksheets further include important information relating to the Swiss tax treaty network as well as the wording of the tax treaties between Switzerland and the United States.


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AUTHORS

Business Operations in Switzerland was authored by the following experts.
PETER R. ALTENBURGER
Peter R. Altenburger, University of Zürich (lic. iur., 1969,); University of Michigan Law School (Master of Comparative Law, 1970); European Institute of Business Administration, Fontainebleau, France (M.B.A., 1971); University of Basle (Dr. iur., 1977); admitted to Swiss bar; member, Swiss and International Bar Association, American Bar Association (International Associate), International Fiscal Association, and Tax Chapter Board of the Swiss-American Chamber of Commerce (Zürich).

JOSEPH J. CZAJKOWSKI
Joseph J. Czajkowski, Georgetown University (B.A., 1971); studied in the Faculty of Law, University of Fribourg (Switzerland); Boston College Law School (J.D., 1975); Georgetown University Law Center (LL.M. Taxation, 1979); admitted to bar, District of Columbia (1976), Texas (1992); member, American Bar Association Section on Taxation, International Fiscal Association, and Tax Chapter Board of the Swiss-American Chamber of Commerce (Zürich).

MASSIMO G. CALDERAN
Massimo G. Calderan, University of Zürich (lic. iur., 1986); admitted to Swiss bar; member, Swiss, Zürich and International Bar Association; Swiss-Italian Chamber of Commerce (Zürich), consultant; OSEC (Business Network Switzerland), consultant.

WERNER LEDERER
Werner Lederer, University of Zürich (lic. iur., 1988); Swiss Certified Tax Consultant (2000); member, Swiss Institute of Certified Accountants and Tax Consultants, International Fiscal Association, International Bar Association.

TABLE OF CONTENTS

Detailed Analysis

I. Switzerland - the Country, Its People, and Economy

A. Geography, Climate and Population

B. Languages

C. Short History

D. Political System

E. Memberships

F. Switzerland and the European Union

G. Economy

1. In General

2. Switzerland's Resources

3. Foreign Inbound Direct Investment in Switzerland

4. Swiss Outbound Direct Investment in Foreign Countries

5. Foreign Trade

II. Operating a Business in Switzerland

A. Key Considerations for Foreign Investors Establishing a Business in Switzerland

B. Ten Useful Addresses in Switzerland

C. Foreign Investment Regulations

1. Foreign Investment Policy

2. Incentives and Tax Privileges

3. Few Restrictions on Foreign Inbound Investments

D. Trade and Commerce Regulations

1. Imports

2. Customs Duties

a. Regular Rates

b. Preferred Rates

c. Customs Clearance - Documentation

d. Storage Facilities - Bonded Warehouses

3. General Regulation of Business

a. Unfair Competition

b. Monopolies and Antitrust

c. Price Control

d. Merger Control

e. Disclosure of Substantial Shareholdings

f. Tender Offers

4. Licensing and Franchising

a. Patents

b. Patent Licenses

c. Trade Names

d. Trademarks

e. Franchises

f. Trade Secrets and Know-How

g. Copyright and Neighboring Rights

E. Labor Relations and Work Permits

1. Availability of Labor

2. Unions

3. Work Permits

a. In General

b. European Union/European Free Trade Association Nationals

(1) Free Movement of Persons from European Union/European Free Trade Association Member States

(2) Categories of Permits

(a) Residence without Residence Permit but with the Obligation to Register

(b) European Union Short-Term Residence Permits ("EU L Permits")

(c) European Union Residence Permits ("EU B Permits")

(d) European Union Cross-Border Commuter Permits

(e) Settlement Permits ("C Permits")

(3) Application Procedure

c. Third Country Nationals

(1) Categories of Permit

(a) Short-Term Residence Permits ("L-Permits")

(b) Year-Round Residence Permits ("B-Permits")

(c) Cross-Border Commuter Permits ("G-Permits")

(d) Settlement Permits ("C-Permits")

(2) Application Procedure

F. Banking and Finance

1. In General

2. The Financial Markets

a. Securities Market

b. Conditions for a Swiss Stock Exchange Membership

c. Listing Requirements

d. Capital Market

e. Single European Currency - Euro

f. Money Market

g. Insider Trading

h. Stock Price Manipulation

3. Swiss Banking Secrecy

a. Scope of Swiss Bank Secrecy

b. Disclosure of Customer's Identity

c. Money Laundering

d. Swiss Bank Secrecy and Foreign Disclosure Requests

G. Real Property Laws

1. Real Property Register

2. Mortgage Loans

3. Limitations on Foreigners Acquiring Swiss Real Property

III. Forms of Doing Business

A. Principal Business Entities

1. Statutory Restrictions

2. Incorporated Entities

a. Stock Corporation (Aktiengesellschaft)

b. Limited Liability Company (Gesellschaft mit beschrankter Haftung)

3. Unincorporated Entities

a. (Simple) Partnership (Einfache Gesellschaft)

b. General Partnership (Kollektivgesellschaft)

c. Limited Partnership (Kommanditgesellschaft)

4. Other Business Organizations

B. Stock Corporation (Aktiengesellschaft)

1. Formation

a. Corporate Name

b. Purpose Clause

c. Share Capital

d. Shares

e. Participation Certificates

f. Profit Sharing Certificates

g. Incorporation Procedure

h. Costs of Incorporation

2. Operation

a. License

b. Shareholders' Meetings

c. Board of Directors

d. Statutory Auditors

e. Books and Records

f. Regular Increases in Share Capital

g. Increases in Authorized Share Capital

h. Conditional Increases in Share Capital

i. Reduction of Share Capital

3. Dissolution and Liquidation

4. Dissolution by Merger

a. Statutory Mergers

b. Exchange of Shares

C. Limited Liability Company (Gesellschaft mit beschrankter Haftung)

1. Introduction

2. Formation

a. Purpose Clause

b. Company's Share Capital

c. Shares

d. Incorporation Procedure

e. Appointment of Auditors

f. Company Name

g. Organizational Bylaws

h. License to do Business

i. Costs of Incorporation

3. Organization

a. Members' Meeting and Company Resolutions

b. Management and Supervision

c. Books and Records

d. Increase in a Limited Liability Company's Share Capital

e. Reduction of a Limited Liability Company's Share Capital

4. Withdrawal

5. Dissolution and Liquidation

D. Agency and Distributorship

1. Penetrating the Swiss Market

2. Agency

3. Distributorship

E. Branches of Foreign Entities

1. General Remarks

2. Registration of a Swiss Branch

3. Jurisdiction

IV. Accounting and Auditing

A. Overview

B. Accounting

1. Accounting Principles

2. Form and Content of Statutory Accounts

a. General Remarks

b. Statutory Profit and Loss Statement

c. Statutory Balance Sheet

d. Appendix

e. Annual Report of the Board of Directors

f. Cash Flow Statement

3. Statutory Asset Valuation Principles

a. Fixed Assets

b. Current Assets

4. Provisions and Reserves

a. Contingency Provisions

b. Reserves

c. Hidden Reserves

d. Inflation Accounting

5. Consolidated Accounts

a. In General

b. Duty to Prepare Consolidated Accounts

c. Consolidation Principles

6. Publication of Accounts

C. Auditing

1. Audits

2. Reviews

3. Professional Requirements for Auditors

4. Liability of Auditors

V. Overview of Tax System

A. Income from Direct and Indirect Taxes

B. Legal System

1. Constitutional Basis

2. Principal Tax Statutes

a. Federal and Cantonal Income Tax Acts

(1) Income Tax Harmonization

(2) Income Taxes

(3) Cantonal Capital and Net Wealth Taxes

b. Federal Withholding Taxes

(1) In General

(2) Dividends

(3) Interest

(4) Royalties

(5) Distributions Made by Resident Investment Funds

c. Federal Stamp Taxes

(1) Issue Stamp Taxes

(2) Turnover Stamp Taxes

d. Value Added Taxes

3. Ordinances and Circular Letters

4. Tax Rulings

5. Case Law

C. Tax Administration

1. Tax Authorities and the Collection of Tax

2. Income Taxes

a. Tax Returns

b. Filing of Income Tax Returns

c. Time of Filing Income Tax Returns

d. Assessments

e. Administrative Appeals Procedures

f. Judicial Appeal Procedure

3. Federal Withholding Taxes

4. Value Added Taxes

a. Assessment and Filing Requirements

b. Appeal Procedures

5. Tax Audits

D. Basic Elements of the Income Tax System

1. Time Periods Relevant for Income Taxation

2. Base Period

3. Tax Period

4. Assessment Period

5. Postnumerando System

6. Basic Principles of Swiss Income Taxation

a. Economic Performance Principle (Leistungsfaehigkeitsprinzip)

b. Worldwide Income Taxation - Sources of Income

c. Taxation of Capital Gains

d. Shareholders and Corporations - The "Classical" System

e. Intercompany Transactions - Dealing at Arm's Length

f. No Filing of Separate Tax Accounts

g. The Relevant Commercial Form Principle (Massgeblichkeitsprinzip)

h. Imparity Principle (Imparitaetsprinzip)

7. Tax Avoidance, Penalties and Professional Secrecy

a. Tax Avoidance

b. Penalties

(1) Late Filing

(2) Tax Evasion

(3) Tax Fraud

c. Protection of Professional Secrecy

VI. Taxation of Resident Corporations

A. Definition of Resident Corporations for Tax Purposes

B. Tax Base

C. Calculation of Gross Income

1. Inventory Valuation

2. Capital Gains

3. Interest

4. Intercompany Interest Income

5. Dividends

a. In General

b. Participation Deduction

c. Calculation of Participation Deduction

6. Royalties and Service Fees

7. Foreign Exchange Gains and Losses

8. Nontaxable Items

9. Transactions Having No Impact on Taxable Income

D. Business Expenses

1. In General

2. Tax Write-Off of Inventories

3. Depreciation

4. Provisions

5. Investment Credit Allowances

6. Interest Expense

a. Debt-to-Equity Requirements

b. Intercompany Interest Charges

7. Intercompany Management and Service Fees

8. Royalties

9. Rents and Leasing Expenses

10. Charitable Contributions

11. Incorporation Expenses

12. Recession Reserves

13. Social Insurance Contributions

14. Taxes

15. Nondeductible Items

a. In General

b. Hidden Profit Distributions

c. Payment of Bribes

16. Losses

E. Computation of Corporate Income Tax

F. Computation of Capital Tax

VII. Taxation of Nonresident Corporations

A. Definition of a Nonresident Corporation

B. Federal Withholding Taxes - Refund System

C. Federal Withholding Taxes - Reporting System for Dividends

D. Foreign Corporations Subject to Federal Income Tax - An Overview

E. Income Derived from Swiss Partnerships

F. Income Derived from Swiss Real Property Operations

G. Income from Swiss Mortgage Loans

H. Foreign Dealer in Swiss Real Property

I. Income Derived from a Swiss Permanent Establishment

1. Treaty Taxation Principle

2. Definition of a Permanent Establishment

a. In General

b. Treaties

3. Principles of International Taxation as Regards Permanent Establishments

4. Income Attribution Methods

a. In General

b. The Direct Method

c. Unitary Method

d. Swiss Tax Treatment of Foreign Head Office Losses

5. Expense Allocation Method

6. Determination of Capital Subject to Tax

7. Tax Rulings

8. Tax Rates

9. Branch vs. Subsidiary in an International Context

VIII. Taxation of Acquisitions, Reorganizations and Liquidations

A. Acquisitions

1. Exchange of Shares (Merger-Like Transactions)

2. Acquiring the Assets of a Swiss Target

3. Acquiring the Shares of a Swiss Target

a. Domestic Sellers

b. Foreign Sellers

B. Reorganizations

1. Converting an Operating Company into a Holding Company

2. Interposing a Swiss Holding Company

a. Domestic Issues

b. Foreign Issues

3. Mergers

a. Regular Mergers

b. Parent-Subsidiary Mergers

4. Spin-Offs and Split-Offs (Demerger)

5. Transformation

a. Transformation of a Partnership into a Legal Entity

b. Transformation of a Legal Entity into Another Legal Entity

6. Intra-group Transfers of Businesses, Business Divisions, Equity Rights and Fixed Assets

C. Liquidation of a Swiss Company

1. Income Tax

2. Liquidation Tax

3. Withholding Tax

IX. Special Corporate Tax Regimes

A. Attempts to Align Cantonal Tax Regimes

B. Holding Companies

1. The Cantonal Income Tax Regimes

2. Cantonal Capital Tax Charges

3. The Federal Participation Deduction System

C. Domiciliary Companies

D. Mixed Domiciliary Companies

E. Newly Established Enterprises

F. Finance Branches

X. Taxation of Foreign Operations

A. In General

B. Exemption with Progression Method

C. Foreign Tax Credit

D. Foreign Tax Deduction

XI. Taxation of Resident Partnerships and Joint Ventures

A. Domestic Partnerships - Resident Partners

B. Domestic Partnerships - Nonresident Partners

C. Domestic Joint Ventures Involving Resident and Nonresident Partners

XII. Taxation of Resident Individuals

A. Overview of Direct Taxes Affecting Resident Individuals

1. Income Taxes

2. Taxation of Capital Gains

3. Federal Withholding Taxes (On Passive Income)

4. Wage Withholding

5. Other Taxes

B. Residence

1. Domestic Provisions

2. Treaty Provisions

C. Income Taxes

1. Income

a. Business Income of Self-Employed Individuals

b. Employment Compensation

(1) Salaries

(2) Lump-Sum Expense Allowances

(3) Cost-of-Living Allowances

(4) Housing and Schooling Allowances

(5) Pension Plan Contributions

(6) Use of Firm Car

(7) Tax-Equalization Payments

(8) Severance Pay

c. Employees' Stock Purchase and Stock Option Plans

(1) General Remark

(2) Stock Purchase Plans

(3) Stock Option Plans

d. Other Relevant Income Items

(1) Spouse's Income

(2) Income from Ancillary Activities

(3) Capital Gains on Movable Nonbusiness Property

(4) Capital Gains on Immovable Property

(5) Income from Portfolio Investments Including Foreign Currency Gains

(6) Rental Income

(7) Deemed Rental Value (Eigenmietwert)

(8) Alimony and Support Payments

(9) Social Security, Pension Plans, and Insurance

(10) Other Income

2. Deductions

a. General Principle

b. Spouses Salary

c. Interest on Debt

d. Alimony and Support Payments

e. Social Security Contributions (AHV/IV/EO/ALV) (First Pillar)

f. Pension Scheme Contributions (Second Pillar and Third Pillar A)

g. Insurance Premiums

h. Costs Charged by Custodians

i. Noncreditable Foreign Withholding Taxes

j. Contributions to Political Parties

k. Contributions to Legal Entities of Public Interest

l. Social Deductions

m. Nondeductible items

3. Tax Computation and Tax Rates

a. Three-Tier Taxation

b. Federal Income Tax

c. Cantonal and Municipal Income Taxes (Taking the Canton and City of Zürich as an Example)

(1) Base Amount (Determined in Accordance with Progressive Rates)

(2) "Factor" or "Multiplier"

(a) Cantonal Multiplier

(b) Communal Multiplier

(c) Calculation

d. Examples From Other Cantons

D. Net Wealth Taxes

1. Federal Level

2. Cantonal Level

3. Assets Included

a. Bank Accounts

b. Securities

c. Household and Personal Effects

d. Life Insurance

e. Real Property

f. Real Property Situated Outside the Taxpayer's Canton of Residence

4. Personal Debts

5. Calculation

E. Withholding Taxes Affecting Passive Income

1. Income from Domestic Sources

2. Income from Foreign Sources

F. Social Security and Pension Arrangements

1. General Overview

a. First Pillar

b. Second Pillar

c. Third Pillar

2. The First Pillar - Old Age, Survivors and Disability Plan

a. Premiums

b. Lump-Sum Payments

c. Annuities

(1) Federal Income Tax

(2) Cantonal Income Tax (Taking Zürich as an Example)

3. The Second Pillar - Collective Pension Plans

a. Premiums

b. Lump-Sum Payments

(1) Federal Income Tax

(2) Cantonal Income Taxes (Taking Zürich as an Example)

c. Annuities

(1) Federal Income Tax

(2) Cantonal Income Tax (Taking Zürich as an Example)

4. The Third Pillar: Individual Pension Plans

a. Scope

b. Premiums

c. Lump-Sum Payments

d. Annuities

G. Taxation of Life Insurance

1. Scope

2. Deductibility of Premium

3. Taxation of Payments

a. Capital Insurance

(1) Repurchasable Capital Insurance (Rueckkaufsfaehige Kapitalversicherungen)

(2) Non-Repurchasable Capital Insurance

b. Annuity Insurance

H. Special Income Tax Regime for the Taxation of Resident Aliens

1. Tax Basis

2. Income Tax Computation

a. Computation Based on Cost-of-Living Expenses

b. Alternative Computation Based on Certain Categories of Income

XIII. Taxation of Nonresident Individuals

A. Nonresidents

B. Categories of Income Taxable in the Hands of Nonresidents

1. Taxation of Active Income

a. Swiss Payroll

b. Participation in Active Swiss Businesses

c. Ownership of Swiss Real Property

d. Trading in Swiss Real Property

e. Permanent Establishment

f. Cross-Border Employees

g. Directors' Fees

h. Performing Artists, Athletes, and Speakers

i. Employees of Swiss Carriers

2. Taxation of Investment Income

a. Dividends and Interest Payments

b. Mortgage Interest

c. Retirees Deriving Benefits from Swiss-Based Pension Plans

(1) Lump-Sum Payments

(a) Federal Tax

(b) Cantonal Tax

(c) International Double Taxation

(2) Annuities

(3) Beneficiaries of Swiss Life Insurance Plans

XIV. Taxation of Estates, Gifts, Foundations, and Trusts

A. Inheritance Taxes and Estate Taxes

B. Inheritance Tax System

C. Gift Taxes

D. Resident Family Foundations

E. Taxation of Trusts

1. Introduction

2. Civil Law Considerations

3. Civil Law Recognition of a Trust Settled by a Resident Alien Settlor

a. Revocable Trusts

b. Irrevocable Trusts

4. Limitations on Setting Up a Trust in Switzerland

a. Applicable Law

b. Public Policy Issues

(1) Forced Heirship

(2) Infringement of Creditors' Rights

(3) Rule Against Perpetuities

5. Tax Considerations

a. General Principles

b. Taxation of Resident Beneficiaries

c. Resident vs. Nonresident Settlors and Beneficiaries

d. Withholding Tax

e. Tax Treaties

XV. Indirect Taxes

A. Federal Stamp Taxes

1. Introduction

2. Issue Stamp Taxes

a. Taxable Transactions and Rates

(1) Issuance of Stock

(2) Issuance of Debt Instruments

b. Tax Liability

(1) Stock

(2) Debt Instruments

3. Turnover Stamp Tax

a. Important Features

b. Taxable Transactions

(1) Securities Dealers

(2) Taxable Securities

(3) Subject to Tax

(4) Tax Exemptions

(5) Tax Rates

(6) Primary and Secondary Market Transactions

4. Stamp Tax on Insurance Premiums

B. Federal Value Added Tax

1. Guiding Principles

2. Territoriality

a. Domestic versus Cross-Border Transactions

b. Goods

c. Services

d. Self-Supplies

3. How the Value Added Tax System Works

4. Output Tax Rates

5. Persons Subject to Value Added Tax

a. Enterprises Carrying on Independent Activity

b. Voluntary Inclusion of Otherwise Excluded Enterprises

c. Consolidated Value Added Tax Returns

d. Autonomous Divisions of Government Entities

e. Import of Services

6. Persons Not Subject to Value Added Tax

7. Transactions Subject to Value Added Tax

a. Imports of Goods and Services

(1) Imports of Goods

(2) Services Supplied by Nonresidents

(3) Triangular Transactions Involving European Union Suppliers

b. Domestic Transactions

(1) General

(2) Supplies of Goods

(3) Domestic Supply of Services

(4) Self-supplies

(5) Corporate Reorganizations

8. Transactions Not Subject to Value Added Tax

a. Unilateral Transactions

b. Exempted Transactions

c. Option for Voluntary Inclusion of Exempted Transactions

d. Zero-Rated Transactions

e. Export Documentation

9. Input Tax Credits

a. General

b. Deduction of Input Tax

c. Mixed Use

d. Predetermined Input Tax Credit Rates

e. Subsequent Right to Deduction of Input Tax

10. Accounting

11. Value Added Tax Refunds

a. Tourists

b. Nonresident Entrepreneurs

C. Cantonal Real Property Transfer Taxes

1. Real Property Taxes

2. Real Property Transfer Taxes

3. Cantonal Real Property Capital Gains Tax

XVI. Avoidance of International Double Taxation

A. Swiss Tax Treaty Policy

1. Avoidance of Double Taxation

2. Intercantonal Taxation Principles

3. Withholding Tax Exemption Applicable with Respect to European Union Member States

4. OECD Model Convention

5. Types of Tax Treaties

B. Income Tax Treaties

1. Scope of Switzerland's Treaties

2. Taxes Covered

3. Persons Entitled to Treaty Protection

a. Individuals

b. Corporations

c. Partnerships

d. Investment Funds

4. Taxation of Business Income

a. General Principle

b. Permanent Establishments Located in Switzerland

c. Foreign Permanent Establishments of Swiss Companies

d. Transfer Pricing

(1) Arm's-Length Principle

(2) Initial Adjustments

(3) Correlative Adjustments

5. Taxation of Swiss-Source Investment Income

a. Investment Income Defined

b. Taxation Principles

c. Dividends

d. Interest

e. Royalties

f. Capital Gains

6. Personal Services

a. Income from a Profession

b. Athletes and Performing Artists

c. Employment Remuneration

d. Director's Fees

e. Pensions

7. Other Income Items

8. Methods of Avoiding Double Taxation

9. Limitation on Treaty Benefits

a. Treaty Shopping Definition

b. The 1962 Abuse Decree

c. The 1998 Circular Letter

(1) Public Company Exemption

(2) Active Company Exemption

(3) Holding Company Exemption

d. Treaty Clauses

e. EU Savings Tax Agreement

f. Nonapplicability

10. Exchange of Information in Tax Matters

11. Competent Authority Procedures

a. General Remarks

b. Competent Authority Procedure

c. Initiating Competent Authority Procedures

d. Preliminary Examination of a Taxpayer's Request

e. Advance Pricing Agreements

f. Arbitration Procedure

XVII. European Union Taxation

A. Switzerland's Bilateral Approach

1. Taxation Issues in General

2. Non-Application of EC Directives

B. Code of Conduct

C. EU Savings Tax Agreement

1. Scope

2. Detailed Analysis of the EU Savings Tax Agreement

a. Paying Agents

b. Individual Beneficiaries

c. Interest Payments

d. Grandfathering

D. EC Cooperation Agreement to Combat Fraud

E. Tax Decisions of the European Court of Justice

1. Role of the European Court of Justice

2. Swiss Views

XVIII. Tax Treaties with the United States

A. Income Tax Treaty

1. Sources of Law

2. Selected Provisions

a. Personal Scope

b. Business Profits

c. Dividends, Interest and Royalties

(1) Reduction of Source Country Withholding Taxes

(2) U.S. Source Income - Qualified Intermediary System and Additional Swiss Withholding

(3) Swiss Payments to United States Beneficiaries

(4) Interest

(5) Dividends

d. Capital Gains

(1) General

(2) Alienation of Immovable Property

(3) Property Attributable to a Permanent Establishment

(4) Sale of Ships and Aircraft

(5) Residual Gains

(6) Transfer Due to Restructuring

e. Limitation on Benefits

(1) General

(2) The 1962 Abuse Decree

(3) Categories of Eligible Persons

(4) Predominant Interest Test

(5) Headquarters Company Test

(6) Public Company Test

(7) Swiss Family Foundations

(8) Activity Test

(9) Derivative Benefits Test

(10) Triangular Cases

(a) Guiding Principles

(b) Exceptions

f. Relief from Double Taxation

(1) General Principles

(2) United States Tax Credit Method

(3) United States Citizens Residing in Switzerland

(4) Swiss Relief Methods

g. Exchange of Information

B. Estate and Inheritance Tax Treaty

C. Social Security Treaty


WORKING PAPERS

Working Papers

Table of Worksheets

Worksheet 1 Prototype Articles of Incorporation for Swiss Corporations (AG)

Worksheet 2 Corporate Income Tax Return for Resident Corporations (Taking the Canton of Zurich as an Example)

Worksheet 3 Corporate Income Taxes - Effective Rates for Federal, Cantonal and Municipal Taxes (Combined)

Worksheet 4 Individual Income Tax Return for Swiss Residents (Taking the Canton of Zurich as an Examples)

Worksheet 5 Individual Income Taxes - Cantonal and Municipal Taxes Combined

Worksheet 6 Swiss Forms 1222 and 1223 - Request for VAT Refund

Worksheet 7 List of Double Taxation Agreements and Related Protocols Signed By Switzerland as of January 1, 2008

Worksheet 8 Relief From Swiss Withholding Taxes

Worksheet 9 Relief from Foreign Withholding Taxes

Worksheet 10 Swiss Form 82 (filed by U.S. Residents)

Worksheet 11 Swiss Form 823 (filed by U.S. Companies)

Worksheet 12 1951 Switzerland - United States Income Tax Treaty

Worksheet 13 1996 Switzerland - United States Income Tax Treaty

Worksheet 14 1951 Switzerland - United States Estate and Inheritance Tax Treaty

Worksheet 15 Agreement Between United States and Switzerland on Tax Information Exchange

Bibliography

OFFICIAL

Selected Laws:

UNOFFICIAL

Treatises:

National Periodicals: