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Withholding tax: simplification in the notification procedure within a group as of January 1, 2023

As of January 1, 2023, the following simplifications have occurred in connection with the notification procedure for withholding tax purposes within a group:

 

  • The notification procedure is now applicable in national and also international (unless a different minimum quota is required by a relevant international agreement) relations already from a participation quota of 10% (previously 20%).

  • The notification procedure is now extended to all legal entities that hold a qualified participation (at least 10%), i.e. also to foundations.

  • The confirmation to be obtained in international relationships for the notification procedure (by means of form 823/B/C) is now valid for five years (previously three years).

The above adjustments provide for fewer liquidity issues if the notification procedure can now also be applied thanks to the reduced minimum ratio, and also for administrative simplifications in general.

 

For any further questions or advice, please contact Remo Merz, Swiss certified tax expert, merz@fineac.ch.

 

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Remo Merz, 21 February 2023

 

Keywords: VAT, Withholding tax, notification procedure