Fidinam & Partners Newsletter - April 2023

Switzerland: Tax changes in force from 01.01.2023

Every year, tax legislation is updated in relation to current developments and also according to the rulings of the Federal Supreme Court and the Tax Appeals Commission.

The news concerns:

Expenditure-based taxation

New share right

Increased deductions for children and needy dependents

Taxation of frontier teleworkers

Italy: Transfer of residence of natural persons from Italy to Switzerland

By means of two recent documents (see Reply No. 73 of 18 January 2023 and Reply No. 173 of 27 January 2023), the Italian Revenue Agency provided its clarifications on the rules applicable in cases of transfer of tax residence from Italy to Switzerland by an individual and on the relevant consequences on the allocation of taxing powers between the two countries.

In the following, after an illustration of the Italian domestic tax provisions and the contractual provisions applicable to this case concerning the transfer of residence to Switzerland, we will proceed to highlight the manner in which these regulations have been applied in the two recent policy measures just mentioned.

United Arab Emirates: new corporate tax law (2023)

On 9 December 2022, the Federal Government of the United Arab Emirates (UAE) published Federal Decree-Law No. 47 (Corporate Tax Law, hereinafter "CTL") introducing Corporate Tax (CT) for legal entities and business activities. The CT will come into force with reference to financial years commencing on or after 1 June 2023 and therefore, in the case of financial years corresponding to the calendar year, from the financial statements closing on 31 December 2024.

Argentina: new reporting regime for international transactions

On 27 December 2022, the Argentine Tax Authority (Administración Federal de Ingresos Públicos, AFIP) published Resolution No. 5306/2022 'Regimen de Informacion complementario de operaciones internacionales' (RICOI) in the Official Gazette, which establishes a new informative regime for certain international transactions.

The purpose of RICOI is to obtain information on international transactions for the effective and efficient assessment and management of international tax compliance risks.