We advise you on all issues relating to the crediting of foreign withholding taxes in Switzerland.

We competently support you in the preparation of applications for the credit of foreign withholding taxes by means of DA-1, DA-2 and DA-3 forms, in the discussions with the cantonal tax authorities or objection or appeal proceedings.

Individuals

  • Verification of the conditions for crediting foreign withholding taxes
  • Completion of forms DA-1 (dividends and interest) and DA-3 (royalties, service income).
  • Support with the assertion
  • Assertion of credit in connection with pensions subject to withholding tax
  • Teaching strategies for maximizing crediting opportunities.
  • Examination of the imputation possibilities for persons who are taxed in Switzerland on the basis of expenditure (lump sum)
  • Representation in objection or appeal proceedings up to the Federal Supreme Court
We are happy to support you
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Legal entities

  • Verification of the conditions for crediting foreign withholding taxes
  • Completion of forms DA-2 (dividends and interest) and DA-3 (royalties, service income).
  • Analysis and optimization of cross-border activities with regard to imputation positions
  • Identification of pitfalls and challenges in the relationship between the imputation method and the OECD minimum taxation (GloBe; introduction as of 1.1.2024)
  • Representation in objection or appeal proceedings up to the Federal Supreme Court
We are happy to advise you
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We support you with...

Completion of forms DA-1, DA-2 and DA-3

Completion of forms DA-1, DA-2 and DA-3

  • Clarification of the application requirements in compliance with the relevant double taxation agreements
  • Preparation of forms DA-1, DA-2 and DA-3
  • Checking of prepared forms
  • Advice on optimizing applications from a Swiss perspective
  • Negotiation of tax rulings in this context.
Tax Planning with a view to crediting possibilities

Tax Planning with a view to crediting possibilities

  • Calculation of creditable withholding taxes for future Tax Planning
  • Assessment of the optimal imputation with regard to the introduction of the OECD minimum taxation (GloBe) as of 1.1.2024
  • Analysis and optimization of individual cross-border activities such as IP onshoring, etc.
Support in objection or appeal proceedings

Support in objection or appeal proceedings

  • Analysis of reimbursement decisions and advice on the various appeal options or opportunities.
  • Preparation of objections or appeals up to the Federal Supreme Court
  • Representation of individuals and legal entities in dealings with tax authorities and courts, respectively

Contact us...

Livio Bucher

The crediting of non-reclaimable foreign withholding taxes in Switzerland is one of my core competencies. My doctoral thesis on this topic, which was published in the iff series of the University of St. Gallen in spring 2023, has provided me with valuable insights that I am happy to share with you.

I look forward to hearing from you. We can conduct our consultation by phone, by video meeting, in person at our office or at yours.

Bucher Tax AG | Hirschengraben 33b, CH-6003 Lucerne | +41 41 311 09 02

Website: www.bucher-tax.ch



More about Livio Bucher

Viktor Bucher

With my knowledge, my many years of experience and my expertise in the international tax field, I can successfully support you in the crediting of foreign withholding taxes in Switzerland.

Contact us for a no-obligation initial consultation. This can take place by phone, by video meeting, in person at our office or at yours.

Bucher Tax AG | Hirschengraben 33b, CH-6003 Lucerne | +41 41 311 09 02

Website: www.bucher-tax.ch



More about Viktor Bucher

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