24.1. Taxation of entertainers and sportspersons under domestic law
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.
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