Tax Structuring & Group Taxation in Switzerland

								
																												Corporate tax structuring, group taxation and cross‑border solutions for Swiss and international groups

Corporate groups face complex tax challenges throughout their development, restructuring and international expansion. Tax issues often arise at critical moments such as reorganisations, acquisitions or divestments, where unresolved risks can delay or even jeopardise transactions.

RSM Switzerland supports corporate groups with tax structuring and group taxation services, helping them anticipate risks, optimise their tax position and align tax solutions with business and strategic decisions, both in Switzerland and internationally.

Corporate tax structuring in Switzerland

Corporate tax structuring involves analysing a group’s legal, operational and financial organisation in order to ensure tax efficiency, compliance and long term stability.

Our specialists advise on the design and review of corporate tax structures, taking into account business activities, intra group flows and the applicable Swiss and international tax framework.

Reorganisations and tax neutrality

Swiss tax law allows tax neutral treatment for certain reorganisations, such as mergers, demergers, hive downs, share for share transfers, asset transfers or conversions, provided specific conditions are met.

In particular, tax neutrality generally requires:

the continuation of tax liability in Switzerland;
the transfer of business assets or investments at tax book values; and
compliance with potential disposal restriction periods or other specific conditions.

Where applicable, tax neutrality may apply for direct taxes, indirect taxes, real estate capital gains tax and real estate transfer tax purposes.

Temporary tax exemptions for restructuring and new activities

Swiss cantonal and communal tax law provides for temporary tax exemptions for newly established companies or for existing companies that fundamentally restructure their activities or develop new business lines of economic importance.

These exemptions may reach up to 100 % for a maximum period of 10 years, subject to strict conditions. Availability and criteria vary depending on the canton and are assessed independently from federal tax exemptions, which apply only in specific regions.

Tax rulings and advance certainty

Tax rulings are written, binding confirmations issued by Swiss tax authorities on the tax consequences of specific situations or transactions, such as reorganisations, transfer pricing models or functional currency matters.

When properly prepared and based on full disclosure of the relevant facts, tax rulings provide legal certainty and significantly reduce the risk of unfavourable tax interpretations in future periods.

Group taxation and tax risk management

Group taxation involves a detailed analysis of the activities, balance sheets, results and projects of each group entity, as well as an assessment of the group’s overall economic and tax strategy.

Too often, tax issues only become visible at the time of a sale, separation of a division or major reorganisation, where unresolved tax risks may delay or prevent a transaction.

Identification and management of group tax risks

We assist groups in identifying, analysing and quantifying tax risks at group level, including intercompany transactions, financing structures, profit allocation and inter cantonal taxation.

Where risks are identified, we propose practical solutions and implement them progressively, in line with business timelines and operational constraints.

Tax optimisation and coordination

Group taxation may involve various tools and mechanisms, depending on the group’s structure and objectives, such as:

transfer pricing management;
refinancing and cash pooling;
dividend flows and remittance strategies;
personnel and mobility related tax matters; and
coordination of corporate income tax and other tax obligations.

Our approach aims to optimise the group’s overall tax burden while ensuring compliance with Swiss and international tax standards.

International groups and cross border structuring

Switzerland is frequently chosen by international groups as a European or regional hub due to its stable environment, extensive treaty network and competitive tax regime.

Foreign groups may operate in Switzerland through various structures, such as operational centres, headquarters, holding companies or mixed structures as part of broader international tax planning.

Support for inbound and international groups

RSM Switzerland acts as a one stop shop for international groups, supporting them with:

the choice of location and business model;
liaison with Swiss authorities;
international and cross border tax planning;
functional and transfer pricing analyses;
preparation of transfer pricing documentation;
establishment of Swiss entities or branches;
access to available temporary tax exemptions.

We accompany international groups from their initial planning phase through to ongoing operations, ensuring clarity, compliance and effective tax control.

How RSM Switzerland supports corporate groups

Our tax specialists work closely with legal and international teams to deliver integrated, pragmatic advice tailored to each group’s structure, activities and strategic objectives.

We support corporate groups throughout key phases such as growth, restructuring, acquisitions, divestments and international expansion, helping decision makers anticipate tax consequences and secure transactions.