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Corporate Tax 2021 a Practical Cross-Border Insight Into Corporate Tax Law

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Corporate Tax 2021 a Practical Cross-Border Insight Into Corporate Tax Law Corporate Tax 2021 A practical cross-border insight into corporate tax law 17th Edition Featuring contributions from: Blackwood & Stone LP M&T Lawyers Schindler Attorneys Brækhus Advokatfirma DA Maples Group Slaughter and May BUREN Monereo Meyer Abogados Tirard, Naudin DQ Advocates Limited Mul & Co Utumi Advogados Nagashima Ohno & Tsunematsu Eric Silwamba, Jalasi and Linyama Walder Wyss Ltd. Legal Practitioners Oppenhoff Waselius & Wist GSK Stockmann Paratore Vannini & Partners Weil, Gotshal & Manges LLP Kyriakides Georgopoulos Pepeliaev Group Law Firm Ropes & Gray LLP Table of Contents Expert Chapters Fiscal State Aid: The Commission Rebuffed 1 William Watson, Slaughter and May Taxing the Digitalising Economy 13 Kat Saunders Gregor & Elizabeth J. Smith, Ropes & Gray LLP Q&A Chapters Austria Luxembourg 19 Schindler Attorneys: Clemens Philipp Schindler & 112 GSK Stockmann: Mathilde Ostertag & Martina Gatterer Katharina Schiffmann Brazil Netherlands 29 Utumi Advogados: Ana Claudia Akie Utumi 122 BUREN: IJsbrand Uljée & Peter van Dijk China Nigeria 36 M&T Lawyers: Libin Wu & Ting Yue 129 Blackwood & Stone LP: Kelechi Ugbeva & Somadina Chidolue Finland 42 Waselius & Wist: Niklas Thibblin & Mona Numminen Norway 135 Brækhus Advokatfirma DA: Toralv Follestad & France Charlotte Holmedal Gjelstad 49 Tirard, Naudin: Maryse Naudin & Ouri Belmin Russia 141 Germany Pepeliaev Group: Andrey Tereschenko & 58 Oppenhoff: Dr. Gunnar Knorr & Marc Krischer Alexandra Shenderyuk Spain Greece 147 64 Kyriakides Georgopoulos Law Firm: Monereo Meyer Abogados: Gustavo Yanes Hernández Panagiotis Pothos, Ioanna Barmpa & & Félix Izquierdo Ahumada Emmanouela Kolovetsiou-Baliafa Switzerland 155 Indonesia Walder Wyss Ltd.: Maurus Winzap, Janine Corti & 72 Mul & Co: Mulyono Fabienne Limacher United Kingdom Ireland 164 81 Maples Group: Andrew Quinn & David Burke Slaughter and May: Zoe Andrews & William Watson USA Isle of Man 174 89 DQ Advocates Limited: Greg Jones Weil, Gotshal & Manges LLP: Devon M. Bodoh, Joseph M. Pari & Lukas Kutilek Italy 94 Zambia Paratore Vannini & Partners: Salvatore Paratore, 182 Riccardo Orlandi & Duccio Landini Eric Silwamba, Jalasi and Linyama Legal Practitioners: Joseph Alexander Jalasi & Mailesi Undi Japan 102 Nagashima Ohno & Tsunematsu: Shigeki Minami Chapter 21 155 Switzerland Switzerland Maurus Winzap Janine Corti Walder Wyss Ltd. Fabienne Limacher 1 Tax Treaties and Residence on a bilateral basis to make sure that the regular parliamentary approval process will be followed. To date, Switzerland has incorporated the BEPS minimum standard in 11 DTTs and it 1.1 How many income tax treaties are currently in force is currently conducting bilateral discussions with other jurisdic- in your jurisdiction? tions to implement the BEPS minimum standard. To date, Switzerland has concluded more than 100 income 1.4 Do they generally incorporate anti-abuse rules? double tax treaties (“DTTs”) and it is seeking to further extend its treaty network. In addition, Switzerland has access to benefits similar to those In recent years, the treaties entered into by Switzerland often in the European Union (“EU”) Parent-Subsidiary Directive and contain specific anti-treaty shopping or anti-abuse provisions. the EU Interest and Royalties Directive through the Agreement However, even if a treaty lacks such a provision, a reservation on the automatic exchange of information (“AEOI”) in tax of abuse of rights is inherent in all tax treaties according to the matters entered into by Switzerland with the EU, which jurisprudence of the Swiss Federal Supreme Court. provides for a withholding tax exemption for cross-border Moreover, Switzerland has enacted unilateral measures payments of dividends, interest and royalties between related against the improper use of tax treaties by way of the Anti- entities. Further, the Federal Council has taken measures to Abuse Decree of 1962 and the subsequent circulars issued by implement the latest recommendations of the Global Forum on the Swiss Federal Tax Administration (“SFTA”). These unilat- Transparency and Exchange of Information for Tax Purposes. eral rules only apply in the absence of a specific treaty provision Furthermore, the Multilateral Convention to Implement Tax to payments made to a Swiss company (i.e. in inbound situa- Treaty Related Measures to Prevent Base Erosion and Profit tions) and are designed to prevent the abuse of Swiss interme- Shifting (“Multilateral Instrument” or “MLI”), which was diary companies. developed to efficiently implement some of the BEPS measures Due to the international tax developments and following the into the existing networks of bilateral DTTs entered into force signing of the MLI, which contains a further-reaching “principle for Switzerland on 1 December 2019 (see question 1.3). purpose test”, the Anti-Abuse Decree was partially repealed in 2017 and transformed into an ordinance. 1.2 Do they generally follow the OECD Model Convention or another model? 1.5 Are treaties overridden by any rules of domestic law (whether existing when the treaty takes effect or introduced subsequently)? Most of the Swiss DTTs follow the OECD Model Tax Convention on Income and on Capital (“OECD MTC”). In the hierarchy of legal norms, international law principally overrides domestic law in case of a conflict. However, the Swiss 1.3 Has your jurisdiction signed the tax treaty MLI and Federal Supreme Court has established a rare exception whereby deposited its instrument of ratification with the OECD? a federal act may take precedence over international law if the Swiss parliament has deliberately legislated in breach of a treaty Switzerland signed the MLI on 7 June 2017 and deposited its (so-called “Schubert practice”). instrument of ratification on 29 August 2019. In Switzerland, the MLI entered into force on 1 December 2019. In this respect, 1.6 What is the test in domestic law for determining the it should be noted that the impact of the MLI on Switzerland’s residence of a company? Has the application of the test treaty network will be limited as Switzerland designated only been modified in response to COVID-19? 12 (out of over 100) treaties that will be amended directly through the MLI. However, Switzerland intends to imple- ment the BEPS minimum standards by renegotiating its DTTs Companies are considered to be Swiss tax resident and thus Corporate Tax 2021 © Published and reproduced with kind permission by Global Legal Group Ltd, London 156 Switzerland subject to unlimited taxation on their worldwide income in Switzerland has not reduced its VAT rates due to COVID-19 Switzerland if: (i) their statutory seat; and/or (ii) their place of so far. However, in order to ease the financial burden on effective management, is/are situated in Switzerland. companies due to COVID-19, the Federal Council has decided These rules have not been modified due to COVID-19, to waive late payment interest on VAT until 31 December 2020. although the relocation or inability of directors and managers to travel may have an impact on the company’s place of effective management. However, to date, the Swiss tax authorities do not 2.3 Is VAT (or any similar tax) charged on all transactions or are there any relevant exclusions? seem to challenge a company’s tax residence because of travel restrictions and other measures enacted due to COVID-19. Taxable transactions subject to VAT include: (i) the supply of goods or services for consideration within the Swiss territory; 1.7 Is your jurisdiction’s tax authority expected to revisit the status of dual resident companies in cases (ii) the purchase of services from abroad (reverse charge); and where the MLI changes the treaty “tiebreaker”? (iii) the importation of goods (import VAT). Certain supplies, in particular financial services, insurance and real estate transactions as well as healthcare, education, culture, Switzerland has made a reservation towards Article 4 of the MLI. sport, social care, gambling and lotteries are exempt from VAT It will therefore not implement the MLI tiebreaker rule into its without credit. In such cases, the taxable persons are not enti- DTTs. At the moment, there is no indication that Switzerland tled to deduct the input tax charged on costs. In addition, certain will reconsider withdrawing this reservation. supplies are classified as tax-exempt with credit or zero-rated, typically in relation to the exportation of goods from Switzerland. 2 Transaction Taxes These transactions allow the recovery or deduction of input tax. 2.1 Are there any documentary taxes in your jurisdiction? 2.4 Is it always fully recoverable by all businesses? If not, what are the relevant restrictions? Switzerland levies the following documentary taxes: Businesses registered for VAT may recover or deduct the VAT One-time capital duty The issuance of new shares by, and capital contributions to, a paid on costs (“input tax”), provided that such costs are attrib- Swiss resident company are subject to one-time capital duty at utable to taxable supplies, including zero-rated supplies. Input a rate of 1% (issuances up to CHF 1 million are exempt there- tax related to supplies of goods or services that are exempt from from). However, a relief for restructurings and migrations as VAT without credit is not recoverable or deductible unless an well as recapitalisations is available. option to tax is available and exercised. If a taxable business makes both taxable supplies and exempt supplies without credit Securities transfer tax for input tax, it may only recover or deduct input
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