International Tax Law
Double Tax Treaties, International Developments, Tax Optimisation
Your goals
Many Swiss enterprises do business abroad. Production, distribution and R&D activities are outsourced; new markets are penetrated; existing sales channels are realigned. Employees are often sent to foreign jurisdictions to work on a project or construction job. In addition, mergers, acquisitions and business reorganisations provide synergies and planning opportunities. On the other hand, international developments such as BEPS (base erosion and profit shifting) and the EU Action Plan require careful and wise actions to protect a group’s reputation.
Our services
- Tax optimisation by preventing double taxation, minimising withholding tax, optimising the flat rate tax credit, adapting the business model (value chain management)
- Corporate tax governance advice (tax policy, tax function management)
- Optimisation of financing (cash pools, treasury centres) and intellectual property structures
- Tax rulings
- Transfer prices (TP policy)
- VAT and customs
- Support for APA and MAP
- Migration and relocation of functions
- Corporate tax law
- Mergers, acquisitions and transactions
- Tax compliance
MME Integrated Approach
International tax law is a cross-border discipline which requires extensive experience and creativity. However, the operational reality of an international group should always be reflected in its tax structure. In addition, increasingly complex compliance requirements (trade compliance, for example) should be considered when entering new markets.
Your team
Dr. Samuel Bussmann
Tax Partner
T +41 41 726 99 73
Email
Dr. Walter Frei
Legal & Tax Partner
T +41 44 254 99 66
Email
Thomas Linder
Tax Partner
T +41 44 254 99 13
Email
Dr. Mónika Molnár
Tax Partner
T +41 41 726 99 66
Email
Andreas Müller
Tax Partner
T +41 41 726 99 71
Email
Christoph Rechsteiner
Tax Partner
T +41 44 254 99 79
Email
Claudio Jenni
Senior Tax Advisor
T +41 44 254 99 66
Email
Daniela Arth
Tax Advisor
T +41 44 254 99 66
Email
Peter Haas
Tax Advisor
T +41 41 726 99 66
Email
Dr. Hagen Luckhaupt
Tax Advisor
T +41 41 726 99 66
Email
Christina Moser
Tax Advisor
T +41 44 254 99 66
Email
Christina Stocker
Tax Advisor
T +41 41 726 99 61
Email
Services Tax
From the magazine
Withholding tax: reform recommendations
The FDF expert group recognises an urgent need for action for a reform of the Swiss withholding tax and presented concrete measures in its report. Among other things, it is recommended not to levy withholding tax on interest investments of domestic legal entities and foreign investors.
Exit taxation: Violation of the AFMP
In its ruling of 26 February 2019 (RS C-581/17), the ECJ qualified the immediate taxation of the increase in value of shares in corporations at the moment of relocation to Switzerland as disproportionate and incompatible with the Agreement on the Free Movement of Persons.
All magazine reportsPublications
Dr. Walter Frei
Rechtsschutz in der Amtshilfe
Dr. Mónika Molnár
Der Vorsteuerabzug unter den Regimen des neuen Mehrwertsteuergesetzes in der Schweiz - EU-Kompatibilität des neuen Mehrwertsteuergesetzes