Swiss Tax e-newsletter - June 2023

The Swiss people have just approved the introduction of a constitutional basis authorising a minimum tax rate of 15% for international active groups. A supplementary tax will be introduced by a temporary ordinance, essentially based on the GloBE rules (Global Anti-Base Erosion Model Rules - Pillar II "Pillar 2") approved jointly by the OECD and the G20 on 14 December 2021. Within a six-year period, the Federal Council will have to submit a law repealing this ordinance.

It is very common for shareholders to borrow money from their own company. This approach is often preferred to a conventional loan, because it offers certain facilities and can be put in place very quickly. In addition to these advantages, this type of borrowing can also have tax benefits. Unlike a dividend, the granting of a loan is not subject to income tax, and the interest paid by the shareholder is deductible from taxable income (within the limits set by tax legislation). However, this type of transaction involves significant tax risks that companies and shareholders need to be aware of.

The summer holidays are just around the corner and HR managers and supervisors soon will be overrun with workation requests for flexible and location-independent work from anywhere. As an attractive employer, many companies want to meet the wishes of their employees in order not to lose them in times of the skilled workers shortage. They therefore want to enable their employees to work from (almost) anywhere in the world, be it for a few days, several weeks or even months per year.