Important information about the reporting of asset management costs

With the release of its report on 'Base Erosion and Profit Shifting' (BEPS), the OECD has launched a rigorous and systematic campaign against tax avoidance. As a result, asset managers will have to operate more transparently in future, for example, under the 'Country by Country' reportings. Here, all profits received and taxes actually paid, plus the number of employees, must be disclosed for each country.

  • Treaty abuse should be avoided.
  • The effects of hybrid mismatches must be neutralised.
  • Reporting obligations are extended – for example the transfer price per country must be documented.
  • Detrimental tax schemes will be opposed.
  • Artificial avoidance of permanent establishment status will be prevented.
  • CFC rules (additional taxation of foreign companies) are to be strengthened.
  • Erosion of the tax base (base erosion) via interest deductions will be limited.

As a direct consequence of BEPS, numerous offshore financial centres are raising the level of their relevant corporate value within their effective jurisdictions. The purpose of this is to conclude a double taxation agreement (DTA). This makes the current corporate value and the corresponding profitability of asset management companies in offshore centres more transparent.

As an asset manager, you will want to keep a watchful eye on BEPS developments in order to identify risks early on.

Our BEPS-related services

  • Advice on the impact of the anti-tax-avoidance campaign.
  • Risk identification.
  • Support for your reporting.

BEPS in a nutshell (klicken um zu vergrößern)

Our expert

Benjamin Koch

Partner and Leader Transfer Pricing & Value Chain Transformation, Zurich, PwC Switzerland

+41 58 792 43 34


Contact us

Markus Prinzen

Partner and Leader Corporate Tax Services, PwC Switzerland

Tel: +41 58 792 53 10