Foreign Real Estate and the New Era of Tax Transparency: What Changes with the OECD Proposal?
In recent years, international tax transparency has undergone a profound transformation. After the implementation of the Common Reporting Standard (CRS) and the automatic exchange of financial account information, global attention is now shifting to foreign real estate holdings. This asset class historically remained outside the scope of automatic reporting. In its latest reports to the […]
Swiss Banking Faces First-Ever AT1 Bond Ruling After Credit Suisse Collapse
Switzerland’s financial sector faces unprecedented uncertainty following a landmark court ruling on the treatment of Credit Suisse’s Additional Tier 1 (AT1) bonds. On October 14, 2025, the Swiss Federal Administrative Court (FAC) determined that the 2023 write-down of $17 billion in Credit Suisse AT1 securities (one of the most significant applications of the post-2008 regulatory […]
Switzerland Confronts Tariff Shock and Accelerates Trade Diversification
Switzerland is facing unprecedented pressure from the United States’ latest tariff regime, which now impacts Swiss exports with one of the highest levels globally: a steep 39% tariff as of August 2025 (note: some exports, such as certain pharmaceuticals and gold, are partially exempt). This development has prompted a comprehensive reassessment of Swiss trade strategy, […]
Two Key Responses: The Italian Revenue Agency Clarifies the Tax Treatment of Foreign Trusts
In May 2025, the Italian Revenue Agency issued two responses to tax rulings that provide meaningful clarification for professionals managing foreign trusts with connections to Italy. Responses No. 144 and 145 address two distinct yet closely related issues: on one hand, the taxation of dividends distributed by Italian companies to foreign trusts; on the other, […]
Trust & Unit Linked Policies: A Strategic Tax Shield for Cross-Border Wealth Planning
By August 2025, recent jurisprudence from the Court of Justice of the European Union has reshaped the landscape for unit linked policies and their fiscal treatment. The ruling has prompted financial institutions and wealth managers to reassess the structure of their insurance-linked offerings. It has also led to increased scrutiny from tax authorities across member […]
Arbitration in Private Wealth: A New Chapter with the Swiss TEF Rules
By July 2025, the Swiss Arbitration Centre will formally implement the Supplemental Swiss Rules for Trust, Estate and Foundation Disputes (TEF Rules), representing a significant evolution in the arbitration framework available for private wealth matters. These new provisions build upon the Swiss Rules of International Arbitration (2021), offering a robust and specialized mechanism to address […]
