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Structure tax-efficiently. Stay compliant. Secure competitive advantages.

Tax advisory for banks and capital market transactions

The current tax landscape for banks

More rules, more complexity, more risk:

Differing tax systems, growing reporting obligations, rising complexity – and shareholders and clients who nonetheless expect tax-efficient and legally sound solutions.

Those who want to succeed in this environment cannot consider tax risks in isolation but must align tax strategy, product design, and operational processes from the very beginning.

Learn about our services

Our multidisciplinary team

Backed by Switzerland’s largest tax team specialised in Financial Services, we serve the country’s leading banks and benefit from deep practical knowledge of the industry. We combine interdisciplinary expertise in tax, legal, and regulatory matters with solid experience in planning national and international structures. Our experts possess deep knowledge of bank-relevant tax law, the tax treatment of financial products, the tax-relevant operational processes, and extensive experience dealing with Swiss tax authorities.

Our services

PwC is the trusted partner for national and international banks – from universal and private banks to cantonal and regional banks and specialised institutions. Our tax team specialised in Financial Services develops solutions tailored to bank-specific tax, reporting, and governance requirements.

We support you across the full lifecycle – from the tax-efficient structuring of business models, legal entity and permanent establishment structures, ongoing tax compliance, operational tax (FATCA / automatic exchange of information / Crypto Asset Reporting Framework CARF), to Pillar II analyses and tax governance advisory. For international tax matters, we draw on PwC’s global network of specialists.

Thanks to our deep understanding of banking processes, we ensure that you receive solutions that are not only technically impeccable but also operationally practical and compliant with regulatory requirements.

Your benefits

Industry expertise in banking and capital markets
One-stop shop for tax advisory (incl. corporate tax, operational tax, transfer pricing, VAT, etc.)
Comprehensive perspective
Large international PwC network

We support you with the following services:

Preparation and review of tax returns and declarations for corporate income tax, withholding tax, stamp duty, and VAT. Deadline monitoring, ongoing communication with tax authorities, and support during tax audits by cantonal authorities or the Federal Tax Administration.

Tax-optimised planning of group structures (incl. branches of foreign banks) as well as fund and investment vehicles; support with restructurings (e.g., mergers, carve-outs).

Support in reclaiming withholding taxes on dividends or interest; for clients of the bank as well as, where applicable, on the bank’s own account.

Tax-efficient planning of intra-group and external financing (e.g., bond issuances, securitisation), planning of cash pools and treasury centres.

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

Tax planning and advice related to banks’ crypto service offerings, decentralised finance (DeFi) transactions, and other blockchain-based business models.

Analysis and optimisation of VAT treatment of banking services, outsourcing and service models (taxability, exemptions, input tax deduction), as well as support with registration, declaration (in particular the calculation and review of the input tax lump-sum for banks), and process design. More on VAT here.

Preparation and obtaining of tax rulings to ensure legal certainty and predictability.

Tax analysis and documentation of intra-group service and remuneration structures, including benchmarking studies and transfer pricing studies. More on Transfer Pricing here.

Support in analysing obligations under FATCA, QI, common reporting standard (CRS), and the Crypto Asset Reporting Framework (CARF), including support with audits, qualifications, and reporting. Provision of managed services for reporting obligations, leveraging PwC’s leading global software.

Analysis of whether and to what extent a group or fund structure is affected by Pillar II, calculation of the top‑up tax, and building sustainable processes, systems, and governance for ongoing compliance. More on Pillar II here.

Tax structuring and implementation of participation and incentive plans (e.g., share/option plans, deferred compensation models).

Talk to our experts

Please send us your message via the contact form. We look forward to hearing from you.

Treasury centres: Tax domicile decoded

Martin Büeler

Partner, Leader FS Tax, Zurich, PwC Switzerland

+41 58 792 43 92

Martin Burri

Partner, Corporate Tax Financial Services, PwC Switzerland

+41 58 792 45 00

Benjamin De Zordi

Partner, Corporate Tax Financial Services, PwC Switzerland

+41 58 792 43 17

Roland Reding

Partner, VAT Financial Services, PwC Switzerland

+41 79 540 32 49

Gilles Widder

Director, VAT Financial Services, PwC Switzerland

+41 58 792 82 51

Luca Poggioli

Managing Director, Tax & Legal Services, Zurich, PwC Switzerland

+41 58 792 44 51

Matthias Staubli

Director, Financial Services - Operational Taxes, PwC Switzerland

+41 58 792 19 23

Sandra Barke-Baumgartner

Partner, Corporate Tax Financial Services, PwC Switzerland

+41 58 792 94 34

Fabienne Boinnard Leuba

Director, VAT Financial Services, PwC Switzerland

+41 58 792 84 24

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