Swiss taxation of trusts currently and in the future

At the International Trust & Tax Planning Summit Conference,held from 30 October to 1 November 2006 in Coral Gables, Florida,Frédéric Vuilleumier considered the Swiss taxregime in a paper entitled ‘Inbound Guide: What ShouldYou Do When Assumptions Change?’ In this article, theSwiss direct tax system was discussed and the distinction madebetween federal and cantonal taxation, tax residence in Switzerlandand the question of jurisdiction under Swiss private internationallaw and the application of Swiss civil law where Swiss courtshave jurisdiction and the applicable law in matrimonial matters.The article is part of that paper and concentrates on the taxtreatment of trusts in Switzerland, the current position andthe impact of the draft circular to accommodate the then expectedaccession of Switzerland to the Hague Convention.