Advisory Notes

TCC Insights

Brief Swiss and cross-border advisory notes for international entrepreneurs, investors and families.

TCC Insights provides concise perspectives on selected Swiss and international tax, relocation, corporate and fiduciary topics. These notes are designed for preliminary orientation and do not replace tailored professional advice.

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Select the insight most relevant to your situation.

01
Swiss Relocation

Relocating to Switzerland

Residence, permits and tax positioning.

September 2026 · Current
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02
Private Clients

UK Non-Dom Reform

Swiss alternatives for mobile individuals.

September 2026 · Current
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03
International Tax

Tax Residence Certificates

Documentation, treaty relief and compliance.

September 2026 · Current
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04
Corporate Structuring

Corporate Residence

Effective management, governance and substance.

September 2026 · Current
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05
Private Clients

Italian-Swiss Trusts

Tax, succession and compliance issues in cross-border trust structures.

September 2026 · Current
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06
Real Estate

Lex Koller and the 2026 Reform Project

Foreign buyers, authorisation rules and the proposed tightening of Swiss real estate restrictions.

September 2026 · Current
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07
International Tax

Switzerland–Italy Tax Cooperation

Exchange of information, treaty position and cross-border compliance.

September 2026 · Current
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08
Compliance

Crypto-Compliance in Switzerland

AML, custody, blockchain services and regulatory expectations.

September 2026 · Current
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09
Corporate & Compliance

Swiss Beneficial Ownership Register

From 1 October 2026, new Swiss transparency rules introduce a federal beneficial ownership register. Companies should review ownership chains, control rights, internal records and reporting responsibilities before the new regime becomes operational.

September 2026 · Current
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10
AML & Regulatory

Swiss AML Reform 2026

The revised Anti-Money Laundering Act enters into force on 1 October 2026 and extends diligence requirements to certain high-risk advisory activities. FINMA is also aligning its ordinance with the new framework and FATF expectations.

September 2026 · Current
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11
Cross-Border Employment

Automatic Salary-Data Exchange from 2027

A new federal act enters into force on 1 January 2027, creating the legal basis for automatic salary-data exchange under Switzerland's agreements with Italy and France. Employers should align payroll and cross-border worker data.

September 2026 · Current
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12
Private Clients

Switzerland Approves Individual Taxation

Swiss voters approved individual taxation on 8 March 2026. The reform will move married couples from joint to separate taxation and changes the way income, assets and child deductions are allocated.

September 2026 · Current
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13
Real Estate & Private Clients

Swiss Homeownership Tax Reform

The 2025 vote triggered a fundamental shift in Swiss homeownership taxation: imputed rental value will be abolished, while deductions for mortgage interest and maintenance will be restricted. Entry into force still requires implementation work.

September 2026 · Current
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14
International Corporate Tax

Swiss Pillar Two Ordinance Under Review

Switzerland is reviewing its minimum-tax ordinance after new OECD administrative guidance. The consultation reflects a deliberate timing choice for parts of the guidance while maintaining the 15% minimum-tax framework for large groups.

September 2026 · Current
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15
International Corporate Tax

OECD Pillar Two Side-by-Side Package

The OECD's January 2026 Side-by-Side package adds simplifications, extends the Transitional CbCR Safe Harbour by one year and introduces new safe-harbour concepts. Multinationals should reassess eligibility rather than reuse prior-year assumptions.

September 2026 · Current
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16
Tax Transparency

Switzerland-EU AEOI Protocol Moves Forward

The Federal Council adopted its dispatch on the amended Switzerland-EU AEOI agreement in June 2026. The protocol aligns the agreement with the revised OECD standard and adds assistance for recovery of VAT claims.

September 2026 · Current
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17
Crypto & Tax Transparency

Swiss CARF Implementation Delayed to 2027

Switzerland will not apply CARF duties in 2026. The federal framework is approved, but partner-state activation remains under parliamentary consideration, so implementation cannot begin before 1 January 2027 at the earliest.

September 2026 · Current
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18
EU Tax Transparency / Crypto

DAC8 Is Live: First EU Crypto Reporting Year

DAC8 applies from 1 January 2026. Crypto-asset service providers must collect information on reportable transactions of EU-resident users during 2026, with the first reporting cycle due in 2027.

September 2026 · Current
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19
Financial Services

Berne Financial Services Agreement in Force

The Berne Financial Services Agreement entered into force on 1 January 2026, creating mutual recognition in selected financial-services segments between Switzerland and the United Kingdom and facilitating cross-border market access.

September 2026 · Current
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20
International Tax / Gulf

Switzerland-UAE Tax Treaty Protocol

The amending protocol to the Switzerland-UAE double tax agreement is in force, with most changes applying from 1 January 2026. It adds treaty anti-abuse and updated mutual-agreement provisions.

September 2026 · Current
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21
International Tax / Middle East

New Switzerland-Jordan Double Tax Agreement

The Switzerland-Jordan double tax agreement entered into force in December 2025, with most provisions applying from 1 January 2026. It expands Switzerland's treaty network in the Middle East and incorporates BEPS anti-abuse standards.

September 2026 · Current
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22
Corporate / International Investment

Switzerland-Saudi Arabia Investment Protection

On 2 September 2026, the Federal Council adopted the dispatch on a new Switzerland-Saudi Arabia investment protection agreement. The treaty is designed to restore protection after termination of the previous agreement.

September 2026 · Current
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23
Sanctions & Compliance

Swiss Russia and Belarus Sanctions Expand

Switzerland expanded its Russia and Belarus sanctions lists in May 2026, adopting listings linked to the EU's 20th sanctions package. Cross-border groups should keep screening and beneficial-ownership controls dynamic.

September 2026 · Current
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24
Corporate Governance & ESG

Swiss Sustainable Corporate Management Act

The Federal Council opened consultation in April 2026 on a new Sustainable Corporate Management Act aimed at strengthening human-rights and environmental duties for large companies while limiting burdens on SMEs.

September 2026 · Current
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25
Private Clients & Tax

Federal Income Tax 2026: Inflation Adjustments

For tax year 2026, federal direct-tax parameters were adjusted for 0.1% inflation to offset fiscal drag. The changes will first affect the tax returns filed in 2027 for 2026.

September 2026 · Current
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26
Tax Compliance & Treasury

Federal Tax Interest Rates 2026

From 1 January 2026, the general late-payment and refund interest rate for federal taxes, duties and penalties is 4.0%, down from 4.5%. Voluntary advance payments of federal direct tax receive 0% interest.

September 2026 · Current
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27
Employment Tax & Ticino

Wage Withholding Tax 2026: Cantonal Tariffs

The FTA has published the 2026 wage-withholding tariff files for all Swiss cantons, including Ticino. Employers should ensure payroll engines, employee master data and tariff codes are aligned with the current files.

September 2026 · Current
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28
VAT & EU Cross-Border

EU VAT in the Digital Age: 2026-2027

The EU is actively implementing the VAT in the Digital Age package. Revised OSS/IOSS guidance was issued in July 2026, ahead of changes applying from 1 January 2027 and broader reforms through 2030 and 2035.

September 2026 · Current
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29
Corporate Structuring

Swiss Holding Companies for International Entrepreneurs

Tax, treaty and substance considerations before establishing an international holding structure in Switzerland.

September 2026 · Current
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30
International Tax

Swiss Lump-Sum Taxation vs Italy’s New Resident Regime

A technical comparison of Swiss expenditure-based taxation and the Italian Article 24-bis regime for internationally mobile private clients.

September 2026 · Current
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31
International Tax

International Taxation of Professional Athletes and Image Rights

Residence, Swiss source taxation, Article 17 treaty allocation and the commercial exploitation of an athlete's name and image.

September 2026 · Current
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32
Private Clients & Succession

Swiss Family Office Structures for International Families

Regulatory perimeter under FinIA, ownership vehicles, substance, transparency and cross-border succession for international families.

September 2026 · Current
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33
Real Estate & Cross-Border Investment

Lex Koller Reform 2026: What the Consultation Tells Foreign Investors

Law in force, the preliminary draft of 15 April 2026, the consultation record and the parliamentary track for foreign real estate acquisition.

September 2026 · Current
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34
Real Estate & Cross-Border Investment

EU Affordable Housing Act 2026: Short-Term Rentals and Housing-Stress Areas

COM(2026) 599 final, the data layer of Regulation (EU) 2024/1028, the proposed housing-stress thresholds and what they mean for owners and investors.

September 2026 · Current
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