The seminar, in three half days, will be offered:

• Tuesday 17th October 2023
• Wednesday 25th October 2023
• Tuesday 7th November 2023

After an introduction devoted to the notions of subjection and domicile in both federal and cantonal direct tax law and intercantonal double taxation law, as well as in administrative law, several particularly important procedural issues will be addressed. In addition to the issue of the management of the taxpayer register, the taxpayer's obligations to cooperate and the cantonal tax authority's powers of investigation will be examined. There will also be a focus on the course of the procedure in which the taxpayer's tax liability is established, with particular regard to preliminary rulings, and on the consequences of possible intercantonal double taxation. Other issues that will be considered include the relationship between cantonal procedures and the procedure under federal law to determine which canton is competent to levy direct federal tax. Finally, the speakers will address the scope of possible agreements and rulings on tax liability, as well as the risk of criminal proceedings and tax recovery. After the introductory part, the seminar will focus on aspects of intercantonal relations. An in-depth examination of taxation issues in international relations will be the subject of a possible further seminar, depending on the interest encountered, with particular reference to the taxation of business profits and the related deduction of business losses pursuant to Art. 134a of the Tax Act.

Programme and speakers 1st meeting - Tuesday 17th October 2023

The notion of domicile under administrative law
Matteo Cassina
Lawyer and notary public, Vice-President of the Cantonal Administrative Court and President of the Notary Commission of the Canton of Ticino, former President of the Appeal Court of the Canton of Ticino

The notion of unlimited and limited tax liability of natural persons and legal entities according to Ticino's federal and cantonal legislation
Andrea Pedroli
Prof. Dr. iur., President of the Tax Law Chamber of the Court of Appeal of the Canton of Ticino

The notion of tax domicile and residence under intercantonal double taxation law
Samuele Vorpe
Prof. Dr., Head of the Tax Law Competence Centre of SUPSI, of counsel at COLLEGAL Studio legale e notarile Attorneys at law, Lugano

The taxpayer register (functioning and data processing, obligations of municipal and tax authorities and comparison with other cantons)
Isa Grisoni
Deputy Head of Office, Taxation Office, Lugano
Sabrina Piemontesi - Gianola
Lawyer, Master of Advanced Studies SUPSI in Economic Law and Business Crime, Vice-Chancellor at the Tax Law Chamber of the Court of Appeal of the Canton of Ticino
Rocco Filippini
Lawyer, Master of Advanced Studies SUPSI in Tax Law and in Economic Law and Business Crime, Deputy Director of the Taxation Division of the Canton of Ticino

Programme and speakers II° meeting - Wednesday 25th October 2023
The taxpayer's obligations of cooperation in the taxation procedure
Sabrina Piemontesi - Gianola
Lawyer, Master of Advanced Studies SUPSI in Economic Law and Business Crime, Vice-Chancellor at the Tax Law Chamber of the Court of Appeal of the Canton of Ticino

The powers of assessment available to the cantonal tax authority
Andrea Pedroli
Prof. Dr. iur., President of the Tax Law Chamber of the Appeals Court of the Canton of Ticino

Taxation decisions and the statute of limitations of the right to tax (report in French)
Daniel de Vries Reilingh
Prof. Dr. iur., Lawyer, LL.M., Certified Tax Expert, de Vries Reilingh Legal & Tax SA, Neuchâtel and Lausanne

Christian Chillà
Associate lawyer, MCE Avocats, Lausanne

Ascertaining the place of taxation under Article 108 LIFD
Claudia Genini
MLaw, Attorney-at-law, CIS tax expert, collaborator at the Law Division, Main Division Direct Federal Tax, Withholding Tax, Stamp Duty of the FTA, Bern

Chiara Albisetti
MLaw, Attorney-at-law, CIS tax expert, collaborator at the Legal Division, Main Division of direct federal taxation, withholding tax, stamp duty of the FTA, Bern

Programme and speakers 3rd meeting - Tuesday 7th November 2023
Procedural issues in cases of intercantonal double taxation (appeal to the Federal Supreme Court, forfeiture of the right to tax and the principle of good faith)
Toni Hess
Dr. iur., Head of Legal Services of the Tax Administration of the Canton of Graubünden
Samuele Vorpe
Prof. Dr., Head of the Tax Law Competence Centre of SUPSI, of counsel at COLLEGAL Studio legale e notarile Attorneys at law, Lugano

Ruling and tax agreements in the area of taxation
Alberto Lissi
Dr. iur., Tax Expert dipl. fed., Lawyer, Tax Partner AG, Zurich
Luca Aspesi
Lawyer, Tax expert dipl. fed., Advisor, Tax Partner AG, Zurich

Tax recovery and tax evasion procedures in intercantonal relations (report in French)
Raphaël Gani
Dr. Avv., Tax Expert CSI, Judge at the Cantonal Court of Vaud, Lausanne

Tuition fee
CHF 900
CHF 600 for members of partner institutions

Registration
https://bit.ly/seminari-assoggettamento

Registration deadline
Friday 13 October 2023