Tax
The tax group advises and assists its clients – in Switzerland and in France – in both domestic and international contexts, in the following areas:
Tax Advice for Individuals: Swiss and French Law and Cross-Border Aspects
- Structuring strategy for private assets (acquisition, conservation, growth, divestment and transfer)
- Transfer of businesses in a family context (family agreements, family governance)
- Domestic and international real estate structuring of assets for use, for benefit in kind (vineyard, stud farm) or for income; private or collective ownership vehicles
- Tax liability of trusts, foundations and other entities/structures under foreign law
- Advice on specific assets, in particular art objects
- Philanthropy in a context of asset structuring (charitable foundation, endowment etc.)
- Issues related to fiscal residence (determination, expatriation/impatriation, justification, declaration)
- Expertise regarding transfer of domicile, including assistance in obtaining residency permits
- Audits and tax liability assessment for individuals and family groups
- Assistance with tax returns (income and wealth tax) and other reporting obligations (donation, inheritance, real estate capital gains, exit tax etc.), especially in cross-border situations
Business Tax Advice
- Assistance with the structuring and set up of business enterprises (types of vehicles: company limited by shares, association, foundation, subsidiary, holding company, branch, permanent establishment)
- Assistance during operations of closure, liquidation, transfer of headquarters (migration), restructuring, financing
- Problems of business tax liability in Switzerland and in France, especially regarding cross-border activities/operations
- Coordination of multijurisdictional projects
Relations with Tax Authorities / Tax Litigation
- Assistance with tax audit, negotiations and prelitigation stages
- Assistance with inquiries and investigations (special investigations, searches, seizures, auditions etc.)
- Assistance with administrative jurisdictions and judiciaries during tax litigation
- Assistance with the tax aspect of procedures initiated by criminal prosecution authorities
- International administrative assistance with tax and criminal/tax matters (judicial assistance), automatic exchange of information (AEOI), spontaneous exchange of information
- Interface for non-residents (domiciliation and representation)
- Assistance with the regularisation of complex tax matters (voluntary disclosure), especially related to ownership of financial or real-estate holdings
