In recent years, tax conflicts between Cantons have increased exponentially, and numerous decisions have been rendered by the Federal Supreme Court in this field. The Court’s recent case law will be the main focus of the event: the rules governing the determination of the tax domicile of natural persons and legal entities will be presented. In particular, the criteria to be considered in establishing the prevailing tax domicile will be examined in light of the most recent decisions of the Federal Supreme Court.
With regard to preliminary decisions on tax liability in a Canton, the case law of the Supreme Court has clarified their legal nature and scope of application. Of particular importance is the question of whether it is possible to bring an appeal before the Federal Supreme Court against a tax assessment decision that gives rise to a case of intercantonal double taxation, even when a preliminary decision has become final and binding.
Finally, the case law of the Federal Supreme Court concerning a Canton’s ability to sanction a taxpayer for attempted tax evasion when the taxpayer has failed to comply with cooperation obligations will be analysed. The discussion will therefore address whether, and under what conditions, the Canton that risked losing tax revenue as a result of the taxpayer’s conduct may proceed with criminal sanctions, with specific reference also to the practice of the Canton of Ticino.

Programme and speakers
Federal Supreme Court case law on determining the tax domicile of natural persons
Toni Hess
Dr. iur., Head of the Legal Service of the Tax Administration of the Canton of Grisons

Federal Supreme Court case law on determining the tax domicile of legal entities
Simona Genini
Attorney-at-law, LL.M. International Tax Law, Principal, SIGE Consulenze

The effects of the preliminary decision on tax domicile
Andrea Pedroli
Adjunct Professor of Tax Law at SUPSI, President of the Tax Law Chamber of the Court of Appeal of the Canton of Ticino

The risk of tax evasion and attempted tax evasion in cases of intercantonal double taxation
Kathrin Egli Arginelli
Attorney-at-law, LL.M. in International Taxation, Swiss federally certified tax expert, Deputy Director of the Tax Division of the Canton of Ticino

Fee
CHF 350
CHF 300 for FTAF members and partner organisations

Registration
https://bit.ly/webinar-11-02-2026

Registration deadline
Monday, 9 February 2026