ÀÖÓ㣨Leyu£©ÌåÓý¹ÙÍø

We assist financial institutions with all aspects of tax compliance, including Swiss corporate income tax, withholding tax, VAT, stamp taxes and other Swiss taxes, from the preparation of the tax return to the dealings with the tax authorities.Ìý

We leverage from technology, in particular ÀÖÓ㣨Leyu£©ÌåÓý¹ÙÍø’s Digital Gateway, to streamline the tax compliance process.

We assist with the complex tax challenges in today’s financial services environment, providing pragmatic solutions that meet legal and regulatory requirements and industry best practice.

This includes

• Mergers & acquisitions (tax due diligence)
• Structuring / restructuring
• Tax audits
• Tax rulings / tax opinions
• Health checks
• Tax accounting
• Tax classifications of financial instruments using our "Automated Tax Sections" technology -
• Tax suitability analysis of investment products (Tax Guides)
• Tax risk assessments / tax risk management
• Transfer pricing support
• Ongoing tax hotline
• Tax treatment of digital assets (blockchain / crypto / Distributed Ledger Technology (DLT))
  

Our team possesses many years of experience in assisting Swiss and international clients with all aspects of the U.S. Qualified Intermediary ("QI"),ÌýForeign Account Tax Compliance Act ("FATCA") and Automatic Exchange of Tax Information ("AEOI") regimes, as well as all other operational taxes. In particular, we provide:

• Ongoing compliance and reporting support
• QI/FATCA periodic reviews
• Responsible Officer certification support (see our latest survey results here)
• Health checks
• Policy documents & client onboarding forms
• Risk control frameworks
• Flowcharts and checklists
• Trainings tailored to the specific needs of your organization
• Withholding tax / stamp tax / transaction tax support

We assistÌýasset managers and pension funds with a broad range of tax services, including:

• Swiss investor tax reporting (see our flyer)
• Fund structuring / re-structuring
• Investment reviews / tax due diligences
• Swiss and foreign withholding tax reclaims
• Swiss stamp tax analysis
• VAT analysis
• Transfer pricing support

Whilst we work closely with our clients to prevent tax disputes, we provide dedicated and pragmatic advice to our clients to support them from the moment a tax dispute arises until it is settled.

We defend the interests of Swiss and foreign financial institutions in tax disputes beforeÌýthe Swiss Federal Supreme Court, Federal Administrative Court and cantonal courts.

ÀÖÓ㣨Leyu£©ÌåÓý¹ÙÍø Switzerland offers a successful tax compliance technology called “Multishore Tax Reportingâ€� (MTR), whichÌýprovides an easy and efficient solution to produceÌýautomated tax reportsÌýfor Swiss and international clients of Swiss banks.

> Learn more about Multishore Tax Reporting

We assist financial institutions with all transfer pricing aspects. Our dedicated Financial Services Transfer Pricing experts will help you to review your transfer pricing setup and to identify risks and opportunities related to the specific intra-group transactions in the financial industry. We can support you in planning sustainable and pragmatic transfer pricing systems adequately to your business needs. Finally, we can also support compliance and manage controversy cases (tax audits, Advance Pricing Agreements between tax authorities, rulings, etc.).Ìý

> Learn more aboutÌýTransfer Pricing Services

We assist financial institutions to understand the tax impact of the implementation of Profit Allocation and Nexus rules (Pillar 1), and Global Minimum Taxation (Pillar 2).

We provide insights into the key challenges which arise with the introduction of BEPS 2.0 and find clear answers to the questions raised by the model rules. In particular, we can offer:

• Workshops
• Impact assessments and gap analysis
• Process definition and structuring
• Project implementation
• Trainings

> Learn more about BEPS 2.0

We support companies in the financial services sector with the tax-efficient and tax-compliant execution of their transactions and business activities related to DLT and blockchain technologies. Our services include amongst others:

• Clarifying the correct VAT treatment and data requirements for all banking services around digital assets (wallet services, custody, trading, staking etc.)
• Supporting the issuance of tokens (Profit tax, Withholding tax, Stamp transfer tax, VAT)
• Assisting with the qualification of tokens for Swiss tax purposesÌý
• Assessing whether transactions involving digital assets are subject to Stamp transfer tax or Withholding tax
• Providing solutions around digital assets / transactions tax reporting & account statements
• Evaluating the tax treatment of investments in crypto assets by individuals
• Providing support regarding the readiness for information exchanges on digital assetsÌý
• Providing tax advice with establishing crypto funds

> Learn more about the topic of DLT or our services in this area