On December 13, 2024, the Federal Council published the report in fulfillment of postulate 22.3396 WAK-N from May 2022 "Avoiding disadvantages for Swiss companies through a uniform taxation practice".
The Federal Council considers the application of the direct beneficiary theory for withholding tax to be justified, but is open to simplifications through extensions of the reporting procedure in the group relationship.
The report is available here.
