§ 50 Verordnung für die Sekundarschule - Jährliche Finanzkompetenz

B.2024.142 · sg (Art. 50 DBG)

Swiss Company Taxation and Treaty Abuse

This provision establishes the basis for unlimited tax liability of the company in Switzerland, which the court confirmed the company was subject to.

A/112/2023 · ge (art. 50 LIFD)

Taxation of Foreign Company Based on Effective Management in Geneva

This article, concerning the corporate income tax attribution based on effective management in Switzerland, was used to confirm the unlimited tax liability of the appellant for the years 2009 to 2014.

BE.2023.19 (Art. 50 und 52 DBG)

Tax Evasion Investigation: Unsealing of Bank Documents Upheld with Redactions

Cited in relation to the tax liability of foreign companies in Switzerland.

I.1.2023.157.158 · sg (Art. 50 und Art. 58 DBG)

Company Tax Liability Based on Statutory Seat Despite Foreign Piercing of Corporate Veil

The court ruled that the taxpayer was subject to unlimited tax liability in Switzerland based on these articles, leading to the setting aside of the zero-tax assessment.

80.2022.259 · ti (Art. 50–52 LIFD)

Swiss Tax Authority v. Foreign Entity (Loss Carry-Forward After Cross-Border Merger)

Cited in connection with the transition from unlimited to limited taxation, relevant to maintaining the tax nexus after the merger.

80.2022.39 · ti (art. 50 LIFD)

Tax Liability Based on Place of Effective Management Versus Statutory Seat

Basis for the confirmation of unlimited taxation concerning federal tax (mentioned in the operative part 4.1).

I.1.2021.15.16 · sg (Art. 50 Abs. 1 lit. f DBG)

Monetary Sanction vs. Procedural Costs Tax Deductibility Appeal

Cited in the reasoning section concerning the tax treatment of sanctions, although the main dispositive relies on the analog application of reasoning.

SB.2021.00046 · zh (Art. 50 DBG)

Loss Carryforwards and Tax Neutrality in Corporate Demerger

This provision is listed in the section detailing the legal norms deemed relevant to the case, but it is not explicitly cited in the final dispositive orders.

I.1.2020.172.173 · sg (Art. 50 DBG)

Unlimited Tax Liability and Disallowed Expenses Upheld

Cited as a legal basis defining when a company is subject to unlimited tax liability based on actual management location for direct federal tax.

I.1.2020.172.173 · sg (Art. 50 DBG)

Tax Liability and Disallowed Expenses of Foreign-Managed Company

Cited as a legal basis establishing the jurisdiction/tax liability that the court upheld in its final decision regarding the appeal.

2019 · zh (Art. 50 DBG)

Cypriot Company Tax Residency Appeal: Place of Effective Management vs. Managing Director's Location

The appeal was dismissed as the court found the company subject to unlimited tax liability based on its actual place of management in Switzerland, as per this article.

80.2017.273 · ti (Art. 50 LIFD)

Foreign Company Subject to Swiss Tax Based on Effective Management Location

Basis for confirming the unlimited taxation of the company in the Canton of Ticino due to effective administration in Switzerland.

CDP.2017.106 · ne (art. 50 LIFD)

Tax Residency Dispute: Effective Management vs. Statutory Domicile

Cited in reference to federal law provisions on taxation based on personal nexus.

SB.2015.00144 · zh (Art. 50 DBG)

Place of Management vs. Registered Seat: Tax Liability Determined by Actual Operations

Used to determine the place of actual management for tax purposes in an international context.

SGSTA.2015.31 · so (Art. 50 DBG)

Hidden Equity Imputation and Depreciation on Swiss Investment Property

Cited to establish the conditions under which the company's tax jurisdiction is located in Switzerland (taxable presence).