Hans Rudolf Habermacher

Tax Partner

Profile

Hans Rudolf joined MME in 2020 and is amplifying the tax practice with his extensive experience in the field of Transfer Pricing. Hans Rudolf is well recognized for his ability to align the operational needs of the clients with the prevailing tax and transfer pricing regulations in a manner which offers clients a real added value. During his of his long-lasting professional experience, Hans Rudolf advised a number of Swiss MNCs in the definition, implementation, documentation and defence of Transfer Pricing models. Based on his extensive experience, Hans Rudolf is able to understand the needs of the clients and offers customized solutions, which meet the requirements of the ever-changing transfer pricing rules on a global basis.

Business activities

  • Support companies in the planning and implementation of cross-border business models and function transfers (Value-Chain Transformation)
  • International tax planning under consideration of the latest international developments and local tax requirements
  • Support companies in the implementation of the Swiss Tax reform (STAF) (Step-up valuation / implementation of patent boxes)
  • Active support in the handling of Operational Transfer Pricing and the elaboration of transfer pricing guidelines
  • Preparation of Transfer pricing documentations (Master / Local files) and benchmark studies
  • Implementation of licence and Business Franchise models on a global basis
  • Support tax payers in transfer price audits and tax disputes (including mutual understanding procedures )
  • Improve the tax risk position by obtaining unilateral or bilateral APAs
  • Implementation of tax compliant management service fee and cost share arrangements
  • Support tax payers in the elaboration of valuation for tax purposes
  • Preparation of intra-group agreements
  • Evaluation of transfer price risks (e.g. with M&A transactions)
  • Define profit attribution to permanent establishments
  • Preparation of second opinions

Education

1985
SEBA Lucerne – Bachelor in Economics & Business Administration

Languages

  • German
  • French
  • English

Practical Experience 

since 2020
Tax/Transfer Pricing Partner at MME
2011-2020
Transfer Pricing Partner, Deloitte Zurich
2001-2011
Transfer Pricing Director, PwC Zurich
1997-2001
CFO with a Swiss principal company
1985-1997
Various functions in the finance area of Swiss MNCs (in Switzerland and abroad)