Employee shareholders are often caught off guard by social security authorities when a distributed dividend is subject to social security contributions in whole or in part because it is reclassified as taxable income. This article outlines current practice and its limitations, arguments against reclassification, and possible future developments.
- Sophia Ritzmann, Petrit Ismajli, Michael Grebe, Olga-Vasiliki PlousiouApril 30, 2026
Impact of MiKaDiv reporting in Germany on Swiss custodians
- International
- Individuals
The reporting procedure for capital gains tax on dividends (MiKaDiv) marks a turning point in Germany’s withholding tax landscape. Starting February 1, 2027, paying agents must submit electronic reports to the Federal Central Tax Office—a requirement that has significant implications for Swiss and other foreign custodians. This article analyzes the new obligations, the information requirements throughout the custody chain, and the consequences of incomplete data reporting for the market position of Swiss custodians.
- Adrian Briner, Tobias StieglerMay 28, 2026
Swiss holding company and German specialists: taxes, social security and permanent establishment risk
- International
- Entreprises
The intra-group deployment of specialized personnel between Switzerland and Germany raises complex tax and social security issues. Drawing on a comprehensive real-world example, this article analyzes six typical scenarios—ranging from a simple service contract to a CEO working from home in the border region. It examines the implications of recent legal changes: the new domestic legal basis for senior executives (Art. 5(1)(a bis) DBG), the revised double taxation treaty between Switzerland and Germany, and the 2025 OECD Model Commentary on the home office as a permanent establishment.
