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Audit Industry, Services, Institutions
More security, more trust: Audit services for national and international business clients
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Audit Financial Services
More security, more trust: Audit services for banks and other financial companies
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Corporate Tax
National and international tax consulting and planning
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Individual Tax
Individual Tax
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Indirect Tax/VAT
Our services in the area of value-added tax
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Transfer Pricing
Our transfer pricing services.
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M&A Tax
Advice throughout the transaction and deal cycle
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Tax Financial Services
Our tax services for financial service providers.
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Financial Services
Consultancy services that generate real added value for financial service providers.
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Advisory IT & Digitalisation
Generating security with IT.
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Forensic Services
Nowadays, the investigation of criminal offences in companies increasingly involves digital data and entire IT systems.
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Regulatory & Compliance Financial Services
Advisory services in the area of financial market law.
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Transaction Services / Mergers & Acquisitions
Successfully handling transactions with good advice.
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Legal Services
Experts in commercial law.
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Trust Services
We are there for you.
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Business Risk Services
Sustainable growth for your company.
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Abacus
Grant Thornton Switzerland Liechtenstein has been an official sales partner of Abacus Business Software since 2020.
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Accounting Services
We keep accounts for you.
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Payroll Services
Leave your payroll accounting to us.
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Real Estate Management
Leave the management of your real estate to us.
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Apprentices
Career with an apprenticeship?!
In general, the limitation period for Swiss taxes is five years, but it can be up to seven years for Swiss withholding tax purposes in case of tax evasion and fraud.
In the event of withholding tax evasion (e.g. non-declaration of hidden profit distributions in case of factual liquidations etc.), the Swiss federal tax authorities generally initiate administrative criminal proceedings and extend these to the board members, who are jointly and severally liable for the withholding tax of the company as taxpayer. The Swiss federal tax authorities typically issue a penal notice against which the taxpayer can lodge an appeal within 30 days and then a penalty order against which the taxpayer can request a decision by the criminal court within 10 days of notification.
Recently, the Swiss federal supreme court has confirmed the long-standing practice that a penal order issued by the Swiss federal tax authorities is deemed to be a first-instance judgment which suspends the limitation period. This is in line with the Swiss Federal Constitution and the European Convention on Human Rights which ensure an assessment through an independent and impartial court.
The Swiss federal supreme court confirmed that from a Swiss withholding tax perspective, hidden profit distributions (i.e. non-cash benefits/benefits in kind to shareholders and related parties) are committed by a company/taxpayer by submitting annual incorrect financial statements to the Swiss federal tax authorities. If the company does not submit annual financial statements to the Swiss federal tax authorities, the start of the limitation period is determined by the expiration of the 30-day declaration period after the shareholders’ meeting approving the financial statements. If the company does not hold a general meeting to approve the financial statements, the limitation period begins 30 days after the latest date for the shareholders’ meeting as per the Swiss corporate law (i.e. six months after year-end plus 30 days).
Thus, it is key that buyers of a Swiss target company carefully negotiate representations and warranties as well as indemnification clauses and their limitations in the share purchase agreement.
Grant Thornton Switzerland is well-positioned and has in-depth knowledge and experience in advising throughout the transaction and deal cycle, including negotiation of share purchase agreements.