Tax advice for asset managers

Preparation and review of tax returns and declarations for income tax, withholding tax, securities transfer tax and Value Added Tax (VAT) purposes. Monitoring of deadlines and ongoing communication with tax authorities, as well as support during tax audits by cantonal authorities or the Federal Tax Administration.

Tax-optimised planning and rationalization of group structures as well as fund and investment vehicles, and support with restructuring (e.g. mergers, carve-outs) in compliance with applicable laws. 

Calculation of taxable income from Swiss and foreign funds for Swiss tax purposes – including publication on the Swiss Federal Tax Administration’s course listings. Supported by state-of-the-art PwC tax reporting technologies for maximum precision and efficiency. 

Tax due diligence on funds and investment structures, and the preparation of due diligence reports.

Claims for refunds of withholding tax on dividends or interest.

Advice on securities transfer tax, planning of business activities from a securities transfer tax perspective, health checks and support with securities transfer tax declarations. 

Analysis and identification of opportunities to improve the VAT position in relation to the tax treatment of management and advisory services as well as fund structures; review of contracts, prospectuses and the accounting system to ensure the audit trail. You can find out more about VAT here.

Tax planning and advice in connection with blockchain-based business models. 

Obtaining rulings at corporate level as well as regarding the classification of funds and investment vehicles to ensure correct tax treatment. 

Tax analysis and documentation of intra-group service and remuneration structures (e.g. remuneration for distribution activities or investment management activities), including the preparation of benchmarking and transfer pricing studies. You can find out more about transfer pricing here.

Support in analysing obligations relating to FATCA, QI, Common Reporting Standard and the Crypto Asset Reporting Framework (CARF), including support during audits. Provision of managed services to fulfil reporting obligations, based on state-of-the-art PwC Global software.

Analysis of whether and to what extent a group or fund structures are affected by Pillar II, calculation of the top-up tax, and establishment of sustainable processes, systems and governance to ensure ongoing compliance with applicable laws. You can find out more about Pillar II here. 

Tax structuring of equity and incentive programmes (e.g. carry models, equity participations or phantom shares).