Switzerland

Services 

International company structures require international advisory methodologies. The globalization and dynamization of the financial markets coupled with the increased pace of product cycles present some real challenges.

Cover FS Tax

Main advising areas at a glance:

 

General tax services for financial services

 

  • Transfer pricing: Transfer pricing reviews and advice
  • M&A and restructuring: Acquisitions/sales, mergers/divisions and the reorganization of subdivisions
  • Leasing: National and international leasing transactions
  • Compliance work: Preparation of tax declarations and review of tax invoices and assessments; filing of objections/appeal procedures; tax enhancements in connection with the preparation of annual financial statements
  • VAT advice and planning and VAT health checks
  • Revenue filing: Advice regarding transactions and the implementation of system adjustments
  • Tax accounting: Review and preparation of deferred tax calculations in accordance with US-GAAP, IFRS etc.; review and preparation of tax disclosures; development of tax strategies for activating loss carry-forwards


Special advisory services for banks/brokers


  • Banks active at the international level: Planning and advice with regard to group structures, operating sites and international transactions
  • Banks active at the national level: Advice provided to private, commercial and investment banks with regard to corporate taxes
  • Custodian business: Advice with regard to stamp tax, withholding tax and foreign withholding taxes, including reclamation procedures
  • Financial products: Assessment of tax management for financial products
  • Equity and fixed income trading: Tax assessment of planned transactions
  • Qualified intermediary advising: QI health checks and QI audits
  • EU interest taxation: Advice, planning and support in the implementation of the CH-EU agreement regarding EU interest taxation in the areas of client information, employee training, system adjustments, investment structures, product classification and categorization


Special advisory services in the insurance area


  • Reinsurance structures: Advice and support in the implementation of captives and other reinsurance structures
  • Insurance companies active at the national and international levels: Planning and advice with regard to group structures, operating sites, international transactions, changes in residence and legal structure
  • Capital gains and loss settlements: Tax planning regarding capital gains and loss settlements
  • Stamp duty on insurance premiums: Advice and health checks in connection with stamp duty on insurance premiums


Special asset management advisory services

 

  • Swiss securities funds and in-house funds: Advice in connection with the establishment of Swiss securities funds and in-house funds, as well as their reorganization
  • Foreign securities funds: Advice in connection with the structuring of foreign securities funds, including evaluation of suitable investment vehicles for tax purposes
  • Private equity and hedge funds: Advice in connection with the structuring of private equity and hedge funds, including evaluation of effective investment vehicles for tax purposes
  • Real estate funds: Advice in connection with the structuring of real estate funds, taking into account the circle of investors and investors' legal domicile, as well as the investment legal domicile
  • Fund management structures: Advice in connection with the establishment of fund management structures which are effective for tax purposes EU interest taxation: Advice in connection with the consequences of
  • EU interest taxation for investment vehicles Funds investors: Advice in connection with the tax consequences of fund investments made by all kinds of investors with differing legal domiciles, including the reclamation of withholding taxes

Charles Hermann

Charles Hermann

Partner, Tax Financial Services

+41 58 249 29 82