November 9th, 2023
from 14:00 to 17:30
In a first step, we will look at the recent changes in practice and thus examine the various case studies on the levying of withholding tax in the context of assessable benefits in cash for certain specific cases (such as renovations, financing, the purchase and sale of goods and/or businesses, as well as other special transactions of any kind that have also been the subject of educational events concerning current developments on the levying of withholding tax). After that, we will turn our attention to the notion of 'benefits assessable in cash' illustrated through a selection and respectively analysis of Federal Administrative Court (FAC) rulings. Afterwards, there will be room for criminal proceedings in the field of withholding tax. After a brief contextualisation of the pre-trial phase, the focus will be on the application of coercive measures such as, in particular, the seizure of assets with a view to the collection of the tax due, as well as its collection on the basis of Art. 12 of the Federal Act on Administrative Criminal Law (DPA). Finally, the topic of withholding tax refunds will be dealt with, with particular focus on the implications of the so-called 'old reserve practice' to the recent 'extended international transposition practice'. In addition, the practice of the FTA will be briefly illustrated on the basis of practical cases.
Programme and speakers
Case studies on withholding tax collection
Alberto Lissi
Dr. iur., Tax Expert dipl. fed., Lawyer, Tax Partner AG, Zurich
Fabio Riva
Tax expert dipl. fed., Head of Group 3, External Audit Division, Main Division Direct Federal Tax, Withholding Tax, FTA Stamp Duty, Berne
Benefits assessable in cash according to the case law of the Federal Administrative Court (FAC): Selected cases
Constant Ghielmetti, Certified Tax Expert, Partner at Kellerhals Carrard, Lugano
Criminal proceedings and Art. 12 DPA
Chiara Albisetti
MLaw, Attorney-at-law, CIS tax expert, collaborator at the Law Division, Main Division Direct Federal Tax, Withholding Tax, Stamp Duty of the FTA, Bern
Matteo Gamboni
Senior Manager, PwC Lugano
Withholding tax refunds: from the problem of old reservations to the recent practice of extended international transposition. A look at FTA practice based on practical cases
Oliver Oppliger
Tax expert dipl. fed., Head of Group 5 Refund Division, Main Division Direct Federal Tax, Withholding Tax, FTA stamp duty, Berne
Elisabeth Pfister
Dr. iur. UZH, Specialist Group 5 Refund Division, Main Division direct federal tax, withholding tax, FTA stamp duty, Berne
Tuition fee
CHF 350.
CHF 300 for members of partner associations
Registration
Registration deadline
Tuesday 7 November 2023