René Matteotti

The determination of tax domicile and the delimitation of permanent establishments are among the most challenging issues in intercantonal and international corporate tax law - especially in constellations with home offices, cross-border infrastructures or competing cantonal tax jurisdictions. Using practical case studies, Philipp Betschart and René Matteotti show how the place of effective management is to be determined, when home office activities constitute a permanent establishment and how profits are to be separated internationally according to the Authorized OECD Approach. The importance of sovereign rulings in the assessment procedure and revision claims in the case of intercantonal double taxation are also dealt with. The solutions provide you with the necessary tools to confidently assess jurisdiction and separation issues and to recognize tax risks at an early stage.

The Federal Supreme Court rulings 6B*90/2024 and 6B*93/2024 of February 3, 2025, raise fundamental questions regarding the criminal liability of tax advisors. The focus is on the requirements for perpetration of tax evasion and incitement thereto, as well as the distinction between permissible tax advice and criminal complicity. The rulings shed light on the different roles of in-house and external advisors and their significance for practice and the application of the law.

Workshop by René Matteotti and Philipp Betschart on the occasion of the ISIS) seminar on June 02 + 03, 2025 entitled "Current cases on intercantonal and international corporate tax law"

Workshop by René Matteotti and Philipp Betschart on the occasion of the ISIS) seminar on June 3 - 4, 2024 entitled "Current cases on intercantonal and international corporate tax law"

Workshop zum interkantonalen und internationalen Unternehmenssteuerrecht von René Matteotti und Philipp Betschart anlässlich des ISIS-Seminars «Unternehmenssteuerrecht 2023» vom 19./20. Juni 2023.