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view in original language (German)Criminal Law on Withholding Tax – Perpetrators and Accomplices, Pitfalls of Self-Assessment
Daniel Holenstein, Lic. iur., examines criminal law relating to withholding tax and the pitfalls of self-assessment. Using four case studies, he addresses issues regarding perpetration, complicity, and the criminal liability of board members and tax advisors.
Refunds in International Transactions
Case studies, detailed solutions, and all slides by Oliver Hulliger from his workshop “Refunds in International Contexts” at the 2026 Withholding Tax Seminar. Get the complete package, featuring a total of 7 real-world cases.
Withholding Tax Collection – Case Studies from ESTV Audits
Markus Pfirter and Laetitia Fracheboud use practical case studies from audits conducted by the FTA to highlight current and recurring issues in the collection of withholding tax. Among other topics, the presentation focuses on the reporting procedure within corporate groups and selected real-world cases.
Procedural Aspects of Withholding Tax
Using four real-world case studies, Dr. iur. Angelica M. Schwarz examines key procedural issues related to withholding tax in 2026—ranging from monetary benefits to cancellation practices and the transfer of contractual rights and obligations. Get all the materials from this workshop, including the expert’s detailed case solutions.
Reporting Procedures and Refunds in the National Context
Markus Küpfer, Lic. iur., uses three case studies to illustrate current issues regarding the reporting procedure and the refund of withholding tax. The focus is on corporate group relationships, the repurchase of treasury stock, and refunds to domestic individuals. Get the materials from this workshop, including all of the expert’s detailed solution guidelines.
Withholding tax continually raises new questions regarding both its collection and refund, especially as the FTA is increasingly focusing on transfer pricing during audits. In this recording, you’ll gain a comprehensive overview of current practices: from tax collection to national and international refunds, as well as reporting procedures, criminal law, and procedural law. Benefit from first-hand case studies presented by experts from the FTA and the consulting industry.
Withholding tax is one of the most significant federal taxes in practice and affects SMEs as well as international corporations. Payments in kind, intra-group financing, or restructuring can trigger significant tax consequences. Since the FTA is increasingly focusing its audits on transfer pricing and a refund based on a double taxation treaty is often only partially possible, withholding tax is becoming a significant cost and risk factor for many companies.
The materials (case studies, solutions, and slides) shed light on current withholding tax practices, both in terms of collection and refunds. In a two-part workshop, case studies from FTA audits will be discussed, including intra-group financing, price adjustments, transfer pricing, and restructurings. This will provide a clear understanding of where the tax administration focuses its attention today and which issues are assessed particularly critically during an audit.
Another focus is on refunds in both national and international contexts, as well as on the reporting procedure. In addition, the workshop will cover criminal law related to withholding tax—particularly issues of perpetration and complicity, as well as the pitfalls of self-assessment—and key procedural law topics. The speakers—from the FTA, law firms, and tax consulting firms—contribute direct experience from both the administrative and practical spheres.
The case studies are designed for experienced tax professionals, corporate tax managers, and consultants who wish to refresh or deepen their knowledge of withholding tax and confidently apply the FTA’s current practices.
