The Resource Cantonal taxation of Swiss permanent establishments of non-resident corporations engaged in construction projects in Switzerland

Cantonal taxation of Swiss permanent establishments of non-resident corporations engaged in construction projects in Switzerland

Label
Cantonal taxation of Swiss permanent establishments of non-resident corporations engaged in construction projects in Switzerland
Title
Cantonal taxation of Swiss permanent establishments of non-resident corporations engaged in construction projects in Switzerland
Subject
Summary
The Swiss Federal Constitution prohibits the double imposition of tax on income and net worth by the cantons, and provides that a Federal law is to be enacted containing provisions for the prevention of intercantonal double taxation. Such a law has not been enacted, and it is the Courts which have laid down the necessary legal rules. The rule which is applied in cases of inter-cantonal double taxation is that construction activities connected with immovable property do not constitute a permanent establishment. In a recent case however the Swiss Federal Court has come to the opposite conclusion in a case involving a non-resident corporation having a permanent establishment in one canton and engaged in construction operations in another canton
Citation source
In: European taxation. - Amsterdam. - Vol. 9 (1969),
Geographic coverage
Europe
Language note
English
http://library.link/vocab/subjectName
  • cantonal tax
  • case law
  • PE
  • construction project
Label
Cantonal taxation of Swiss permanent establishments of non-resident corporations engaged in construction projects in Switzerland
Instantiates
Publication
Label
Cantonal taxation of Swiss permanent establishments of non-resident corporations engaged in construction projects in Switzerland
Publication

Library Locations

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      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.3736660 4.9336932
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