International Corporate Tax Services
International firms face an increased burden of tax risk and compliance due to the increasingly global nature of doing business in modern times. Taxes become increasingly complex when dealing with cross-border transactions, or when doing business in multiple jurisdictions.
We are a tax boutique firm offering sophisticated tax solutions suited to the specific needs of international businesses. From our offices in Zurich, we will ensure that your company is both tax-optimized and tax-compliant.
Our services include:
Tax Structuring for International Businesses and Financial Institutions
We advise corporations upon cross-border tax issues that arise in multijurisdictional transactions and in the context of intra-group tax planning. This includes group planning for multinational corporations as well as inbound and outbound investments to and from the United States.
We help our clients address tax risks in order to optimize their global structures, ensure liquidity through intercompany lending, and addressing risks of challenge by local tax authorities driven by transfer pricing considerations.
Tax Advice for M&A Transactions, Restructurings and Insolvencies
We advise our clients on tax-efficient transactional structures within a single jurisdiction or across jurisdictions. We also support corporations, financial institutions, and financial sponsors to establish or restructure cross-border holdings and investments in tax-efficient ways. We also help clients to restructure their investments in order to adapt to fast-changing commercial and regulatory environments.
Tax Structuring for Investment Fund Sponsors and Private Equity Clients
We work closely with private investment fund sponsors, fiduciaries, and institutional investors to achieve their tax and investment objectives. We advise asset managers upon optimal structures (new or existing) from a tax perspective as dictated by regulatory, legal, and human resource considerations.
We are experienced advising asset managers regarding the tax considerations that result from operating in an international environment (including as concerns the acquisition and disposition of investments, efficient use of capital, and reporting requirements relevant to an AIFM and investors).
Structuring Investments in US Real Property
Non-US persons investing in US real property can lead to a requirement for the individual to file an annual US income tax return. Furthermore, holding US real property directly can lead to US estate taxation (40% tax rate) at the death of the non-US person or gift taxation (40% tax rate) on a lifetime transfer of the property. We help our clients structure their interests in US real property to ensure a favorable result from US income tax, estate tax, and gift tax perspectives.
Tax Compliance & Reporting
We prepare and file on behalf of our clients annual U.S. corporate and partnership tax returns and other international tax filings.
Tax Treaty Qualification & Benefits
Holding structures have come under increased scrutiny from tax authorities in recent years (including under the EU`s recent draft Anti-Tax Avoidance Directive 3). We advise upon treaty qualification for our international clients and manage unnecessary tax leakage taking into account evolving market practices.
We also help our clients pursue U.S. tax refund claims for over-withholding on cross-border investments.
Global Mobility & Executive Compensation
Companies serving customers in multiple jurisdictions can face tax risk in foreign jurisdictions (e.g., income tax and social security) where employees are sent abroad to do business.
We help clients to approach foreign markets in a manner to manage the risk of creating a taxable presence in a foreign country (while taking into account regulatory and immigration considerations).
We also advise companies on employee stock option plans and arrangements germane to the compensation of executives.
Transfer Pricing
Pricing can affect the division of revenues and profits in the context of intra-group transactions. We advise corporate groups concerning intercompany service arrangements, IP licensing transactions, and financing arrangements.