As part of the white money strategy, and especially in cross-border private banking, banks and other financial services providers have launched procedures to confirm private tax compliance of their customers. This pro...
UBS, and a Georg Fischer group pension fund as UBS' customer, asked Pestalozzi to advice on a transfer of the pension fund's complete direct real estate investments portfolio. The transfer was made in exchange for shares in a regulated UBS real estate fund. The deal was particularly challenging from a tax perspective. In addition, the transaction was governed by complex restrictions under local real estate laws which had to be mitigated.
The tax authorities treated the transaction as a leading case and redefined their practice in this area. Pestalozzi advised UBS on all tax and legal aspects of the transaction and negotiated with the tax authorities a way for the real estate asset swap to be made in a tax neutral way.
In a share sale completed on 28 August 2015, Royal Bank of Canada, Canada’s biggest bank by assets and the world’s fifth-largest wealth manager at the end of 2014, sold its Swiss subsidiary Royal Bank of Canada (Suisse) SA to Swiss based Banque SYZ SA. Royal Bank of Canada (Suisse) SA has assets under management of about CHF 10 billion.
Credit Suisse AG requested tax advice for its Insurance Linked Strategies business. Pestalozzi advised Credit Suisse with regard to Catastrophe Bonds investments held through an Irish UCITS set up by Credit Suisse and with regard to the application of the EUSD EU Savings Directive.
Fachbereich & Dienstleistung
Branche & Branchen-Dienstleistung
The European Securities and Markets Authority ("ESMA") has set out rules on – eventually – extending the EU passport to non-EU (including Switzerland) AIFMs (alternative investment fund managers) and AIFs (alternat...
Swiss and foreign companies as well as their board members are compelled to act As of July 1, 2016, bribery in the private sector is subject to stricter rules and could more easily lead to criminal prosecution. Swiss a...
Swiss financial institutions, such as in particular, Swiss banks, are closely monitoring plans to introduce an EU FTT. The tax is likely to be introduced in a form such that it would be owed not only by financial institu...
25.06.2016 Brexit - tax consequences for Swiss / UK cross-border dividend payments / mitigation action required
Dividends paid to or received from UK group companies are exempt from dividend withholding tax under the EU / Swiss Savings Agreement (WHT zero rate). This applies so long as the UK is a member of the EU. The benefits...
24.06.2016 Schweizer Unternehmenssteuerreform
Hintergrund Die Schweiz ist im internationalen Steuerwettbewerb bis heute sehr gut positioniert. Zum einen wegen des im internationalen Vergleich tiefen allgemeinen Steuerniveaus, je nach Kanton. Zum anderen wegen der k...
24.05.2016 Guarantee fee for upstream guarantee?
The terms of upstream guarantees (including cross-stream, as opposed to downstream) will typically limit the guarantee amount to the guarantor company's distributable reserves - in the same way as a dividend distribut...