Switzerland: Tax Authorities

Recent Federal Supreme Court rulings clarify when Swiss taxpayers forfeit their right to reclaim withholding tax on dividends and interest. The critical distinction between negligence and contingent intent determines whether the 35% withholding tax can be recovered, with substantial amounts at stake for those who fail to properly declare income and assets.

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As Switzerland's first QDMTT assessments arrive following the 30 June 2026 filing deadline, taxpayers face complex interpretive questions around the GloBE Model Rules. With no prior Swiss court rulings on Pillar Two matters, this analysis examines the procedural pathways and substantive grounds available for challenging disputed positions, from cantonal objections through federal administrative and supreme court appeals.

Swiss lump-sum taxation is often described as if Switzerland offered a fixed annual tax package for wealthy foreign residents. This is misleading. In legal terms, taxation according to expenditure is a method for calculating a taxable base. It is not a flat fee, a separate tax rate or a Swiss residence permit. The real annual cost is usually driven by the highest relevant calculation input, not by the lowest published minimum.

A Swiss lump-sum tax agreement does not, by itself, give you the right to live in Switzerland. Switzerland may allow qualifying foreign nationals to be taxed according to expenditure, but that tax status is not a residence permit, not a visa category and not a purchase price for Swiss residence.

Should your company pursue a stock market listing or remain private? This analysis examines how public and private capital markets have fundamentally shifted over the past two decades, exploring the strategic implications for entrepreneurs, board members, and CFOs navigating M&A transactions, financing decisions, and exit strategies.

The Swiss Federal Tax Administration has aligned its practice with the Federal Supreme Court decision issued in November 2024 in the face of controversy.

On 2 February 2026, the Regulatory Board of SIX Swiss Exchange ("SIX") announced that, with effect from 2 March 2026, SIX will enable Swiss-domiciled companies listed on recognized foreign stock exchanges...

For decades, Trusts have occupied a peripheral position within the Greek legal order.