Through careful and timely planning and the choice of an appropriate structure, taxes can often be reduced sustainably – sometimes over generations – partially eliminated, or deferred in a liquidity-efficient manner. We comprehensively assess your private and business situation, identify structuring options, for example within the system of tax-free private capital gains, the partial taxation of dividend income, or the deferral of real estate gains tax, and determine the appropriate solution. We then implement it under civil law.

Mergers, demergers, asset transfers, and spin-offs within a corporate group may be carried out in a tax-neutral manner, as the law provides for exemptions and deferrals. However, certain restructurings are subject to blocking periods (generally five years). Early tax planning combined with appropriate implementation under civil law is therefore crucial.

A business succession can be structured in a tax-optimised manner for all parties involved, provided sufficient time is available. Companies are often “too heavy” for succession, either because they have substantial real estate assets or because they hold non-operating investments and assets. At the same time, companies often hold substantial profit carry-forwards or excess cash that is not required for operations. Upstream restructurings, so-called “carve-outs”, are therefore advisable, in particular tax-neutral demergers or the transfer of real estate, retained earnings, or shareholdings to parallel entities.
Dividend policy prior to succession can also be combined with income tax deductions (such as buy-ins to occupational pension schemes (2^nd pillar)). An acquisition holding company offers additional flexibility, as ongoing profits of the transferred company do not flow directly to the successors and trigger income tax there but are instead used at the level of the acquisition holding to repay the purchase price. Income or gift tax consequences for successors can likewise often be avoided – decisive is the correct and timely structuring.

A tax ruling – also referred to as an advance ruling or binding advance confirmation – aims at obtaining a prior, written, and binding confirmation or assurance from a tax authority regarding the future tax treatment of a specific factual situation presented by the taxpayer. By means of a tax ruling, taxpayers gain certainty as to whether and to what extent taxes will be levied if they implement a civil law transaction, such as a company sale.
In Switzerland, tax rulings are currently free of charge and provide taxpayers with legal certainty. At the same time, the tax authority also benefits: it knows in advance the civil law project that taxpayers wish to implement. In a subsequent tax assessment, the authority only needs to verify whether the transaction was implemented as previously presented. We regularly submit tax rulings to various authorities, are familiar with the internal processes of tax administrations, and thus secure tax consequences and mitigate potential tax risks for our clients even prior to implementation.

Every natural person in Switzerland has the opportunity once in their lifetime to disclose previously undeclared income or assets to the tax authorities without incurring a fine. The unpaid income and wealth taxes on these items – including interest – must be paid retroactively for up to ten years prior to the year of disclosure; in return, no tax criminal sanctions are imposed. We guide you confidentially through the entire process and ensure that the disclosure is complete and free of penalties.

If you disagree with a tax assessment or evaluation issued by a tax authority, you may file an objection within the statutory limitation periods. An objection can be particularly worthwhile in cases of unclear administrative practice, valuation issues, or tax questions that have not yet been clarified in court. We assess your prospects of success and represent you in appeal proceedings.

In cross-border situations, international tax treaties apply to prevent income or assets – and in some cases inheritances – from being taxed twice or multiple times in different states. We assist you in coordinating cross-border matters, whether private or business-related, to avoid such double or multiple taxation.
Moving to Switzerland or leaving Switzerland triggers the commencement or termination of tax liability in Switzerland as of the date of arrival or departure. Unlike many other states, Switzerland does not levy an exit tax.