Tax consulting for companies is one of our core competences. We have many years of experience and specialized knowledge in providing advice to SMEs, large companies and corporate groups in all areas of national and international tax law. In collaboration with you, we develop the concept that suits you best. We take a holistic approach to your tax situation and offer you thorough, integrated and solution-oriented tax advice.  

Corporate tax consulting by PrimeTax includes the following services:

  • Analysis of your tax situation and development of sustainable tax strategies in particular implementation of STAF measures such as patent box or super deduction for R&D costs, establishment of tax-efficient holding structures, etc.).
  • Tax advice for relocation projects, e.g., use of the migration step-up, application for tax exemption (so-called tax holiday), withholding tax-efficient structuring in an international context, etc.
  • Tax optimization of intra-group relationships (financing and licensing structures) from a Swiss and international perspective
  • Structuring of tax efficient transactions as well as execution of tax due diligence for acquisitions, disposals of group companies, restructurings such as mergers, spin-offs etc.
  • Establishment of employee participation programs (phantom stock, stock or option plan)
  • Advice on tax and social security law for employees and expatriates
  • Tax compliance, i.e., preparation of tax returns as well as withholding tax and stamp duty declarations, representation and communication with the tax authorities and courts

During restructuring, companies go through a series of complex, rapidly sequenced processes, all with the goal of establishing a more sustainable and, above all, more efficient corporate structure. From the conception to the implementation and the follow-up of your project, our know-how is at your disposal.

Our core areas for restructuring include:

  • Identification of tax uncertainty factors and development opportunities in the conception of restructurings 
  • Planning and implementation of tax-efficient restructurings (transformations, mergers, quasi-mergers, demergers, spin-offs, etc.)
  • Preparation and submission of tax rulings for binding assurance of tax consequences
  • Consulting and assistance in real estate transactions

In addition to economic advantages, mergers and acquisitions as well as divestments also provide opportunities to implement tax-optimized structures. We use our experience to identify financial as well as tax risks and opportunities before and during the transaction phase.

Our core areas with Mergers & Acquisitions include:

  • Advising on M&A transactions on both the buyer as well as the selling side
  • Development of a tax-efficient acquisition or divestment structure that takes operational needs into account
  • Development of the right strategy for corporate financing
  • Assistance in contract negotiations and formulation of tax clauses
  • Carrying out the tax due diligence
  • Preparation and submission of tax rulings for binding assurance of tax consequences

For family offices we provide sustainable and discretionary tax planning. PrimeTax frequently advises entrepreneur families and is familiar with their specific needs. In particular, we place a strong emphasis on personal and family interests.

Our services in the area of family offices are:

  • Advice on the choice of the legal form and the structure of a family office 
  • Establishment of family holding companies, foundations, trusts and charitable foundations in Switzerland and Liechtenstein
  • Advice on real estate transactions and acquisition of alternative assets such as art etc. in Switzerland and abroad
  • Succession planning and division of the family business, e.g. (un)paid transfer of shares to other family members or third parties 
  • Immigration and departure of family members (application for taxation according to expenditure, residence permits, etc.)
  • Anual compliance and reporting obligations

A start-up is confronted with challenges from the very beginning. This can quickly lead to problems and complex situations. However, with early planning and the right partner, tax issues should not be a part of it. PrimeTax can guide you from the inception phase of an idea, through the day of incorporation, to the launch of international business strategies or even an exit.

Our services for start-up companies include:

  • Health check and identification or planning of the needed tax related measures
  • Establishment of the compliance process
  • Tax consulting for funding rounds
  • Support in setting up an employee participation plan (shares or options) or phantom stocks
  • Setting up of the transfer pricing strategy
  • Tax advice on acquisitions, disposals, mergers and restructurings
  • Advice on exit strategies for all types of exits: share deal, asset deal, IPO, IPO via SPAC, etc.

Supporting start-ups is an important fundamental pillar of our company's mission. PrimeTax therefore offers comprehensive support to selected start-ups with convincing, innovative business models without a fee or in exchange for equity interests.

PrimeTax has specialized know-how in emerging technologies and has acquired in-depth knowledge in the Blockchain area. We regularly engage in debates in order to represent the interests of the Blockchain and Fintech industry. 

PrimeTax is member of the Swiss Blockchain Federation and co-heads its corporate tax subgroup.

Our tax services in the emerging technologies sector include:

  • Structuring corporate fundraising by issuing and launching tokens or raising funds through IPOs, ICOs and STOs 
  • Business model transformation into a decentralized autonomous organization (DAO) 
  • Tax classification, valuation, accounting and declaration of digital assets
  • Tax analysis of the implementation of airdrops  
  • Establishment of foundation and association structures in Switzerland and Liechtenstein
  • Obtaining rulings from the relevant tax authorities 
  • Tax planning for companies with a high amount of crypto currencies in their balance sheet 
  • Launching share option programs for employees, in which not only traditional participation rights but also tokens are granted

The preparation of the annual financial statements is usually characterized by deadlines and time pressure. When the deadline arrives the tax positions still have to be correctly accounted for. We support and reduce the workload for you. 

In the area of tax accounting, we offer the following services:

  • Support in the preparation of monthly, quarterly and annual financial statements (stand-alone financial statements and consolidated financial statements)
  • Conversion of US GAAP and IFRS annual financial statements to financial statements in accordance with the Swiss Code of Obligations
  • Calculation of current and deferred taxes (Swiss Code of Obligations, IFRS, US-GAAP, Swiss GAAP FER)
  • Valuation and accounting of uncertain tax positions
  • Support in the preparation of the notes to the financial statements (incl. tax rate reconciliation)
  • Preparation and set-up of a tax reporting system
  • Support regarding conversion and adjustment of accounting to take advantage of tax benefits such as patent box or R&D deduction
  • Customer-specific outsourcing of tax accounting and CFO tasks
  • Support with reporting obligations in connection with the BEPS measures (country-by-country reporting, OECD minimum taxation, etc.)

Tax audits can be challenging for you and your business. The preparation for a tax audit always has to be done carefully. Based on our experience, we know what it takes to accompany a tax audit efficiently and successfully. 

In the context of tax audits, we offer the following services:

  • Initial contact with the tax authorities
  • Provision of an electronic data room for easy and efficient preparation
  • Tax due diligence to identify potential tax risks
  • Determination of an ideal strategy and preparation of a solid presentation of the case
  • Representation or participation in tax audits
  • Analysis of audit results and negotiations with the authorities
  • Initiation and management of appeal and objection procedures

Unlike corporations, a sole proprietorship or partnership is not an independent taxable entity. Each partner pays taxes on the accumulated business income or business asssets as well as the other private income an assets. Attention must be paid to this particular tax situation. 

PrimeTax supports self-employed people with the following services:

  • Establishment of sole proprietorships and partnerships
  • Correct reporting of business profits and assets and transfer to the tax return
  • Tax planning in the event of conversion to a corporation
  • Support in the case of transfer of business related assets (e.g. real estate) to private assets
  • Support in questions of differentiation between private and business assets
  • Tax analysis of professional trading in securities, cryptos or real estate
  • Claiming privileged liquidation taxation at liquidation of a sole proprietorship or partnership

The determination of correct transfer prices for intra-group transactions is becoming an issue of increasing importance for groups, especially as this is also becoming greater a focus of the international tax authorities. PrimeTax, together with its proven network of partners, is at your service.

Regarding Transfer Pricing we offer the following services:

  • Analysis of existing transfer pricing models regarding potential country-specific risks
  • Analysis regarding DAC 6 (8) regulations in the EU 
  • Verification and determination of transfer prices in conformity with third party comparisons (benchmarking)
  • Preparation of the necessary transfer pricing documentation, considering country-specific documentation requirements
  • Preparation and negotiation of Advance Pricing Agreements (APA) 
  • Preparation of tax rulings in connection with intercompany services and transactions
  • Support in dispute resolution and negotiations with tax authorities in the context of tax audits as well as in mutual agreement procedures, arbitration and court proceedings
  • Support in administrative assistance proceedings