24.1. Taxation of entertainers and sportspersons under domestic
24.1.1. Introduction and summary
Due to its central position within Europe, the high general
standard of life, an excellent health-care system and a positive
attitude towards sports, arts and culture, Switzerland has always
been a favoured hub for entertainers and sportspersons to establish
their domicile (e.g. Michael Schumacher, Ana Ivanovic and Johnny
Halliday), as well as a suitable place for international cultural
events and sports competitions (e.g. Diamond League Meeting Zurich,
Swiss Indoors tennis competition in Basel, opera productions at the
Zurich Opera house, etc.). Under both scenarios; from a Swiss
domestic perspective and in light of Switzerland's extensive
international treaty network, the taxation of entertainers,
sportspersons, organizers and many further involved parties is of
key relevance and to be determined on a case by- case basis. After
an assessment of the status quo, planning opportunities can be
identified on a tailor-made basis for any entertainer, sportsperson
and involved third party and should be pre-discussed with the
competent tax authorities.
Because of Switzerland's federal structure, taxes are levied
on the federal level as well as on the cantonal and communal level.
In the field of the taxation of income and wealth, federal
legislation governs federal taxes and provides for framework
legislation on cantonal and communal taxes 3 Cantonal and communal
income and wealth taxes, however, are levied based on cantonal tax
acts. These follow the federal guidelines but provide, in
combination with the respective cantons', judicial and
administrative practices, for diverging detailed regulations among
the Swiss cantons. In practice, it is therefore of outmost
relevance in which canton an entertainer or sportsperson resides
and/or performs his activities.
The personal representatives, who are responsible for administering the estate of someone who has died, generally require a Grant of Representation to allow them to collect in, sell and distribute the deceased's assets.
Some comments from our readers… “The articles are extremely timely and highly applicable” “I often find critical information not available elsewhere” “As in-house counsel, Mondaq’s service is of great value”
Register for Access and our Free Biweekly Alert for
This service is completely free. Access 250,000 archived articles from 100+ countries and get a personalised email twice a week covering developments (and yes, our lawyers like to think you’ve read our Disclaimer).