A foreign group planned to relocate key functions to Switzerland. Through an integrated approach combining tax, legal, accounting, and payroll expertise, the expansion was implemented efficiently – including the assessment of a potential immigration step-up and the establishment of a sustainable operational structure.
Initial situation
The international group intended to expand its operations into Switzerland by relocating selected business functions from abroad. As a first step, it was necessary to determine the legal, tax, and accounting requirements for establishing and operating the planned Swiss presence.
A key challenge was to classify the planned relocation of functions correctly from both a tax and an economic perspective. In particular, it had to be assessed whether the transferred function could be valued and whether this could result in a tax benefit through a so-called immigration step-up.
In addition, several other important aspects had to be addressed. These included establishing sufficient Swiss substance through qualified personnel and a physical presence, ensuring compliance with Swiss employment law, and determining the appropriate timing for commencing operations. Without a holistic approach, there was a risk of tax misallocations, regulatory non-compliance, and inefficient organizational structures.
Our contribution
To ensure a successful expansion, an integrated approach was adopted covering all relevant legal, tax, and operational aspects.
As a first step, a comprehensive analysis of the planned relocation of functions to Switzerland was conducted. This included assessing the potential value of the transferred activities and evaluating the applicability of an immigration step-up. Based on this assessment, the related tax benefits were analyzed and, where appropriate, the necessary discussions and/or tax ruling requests with the competent tax authorities were prepared.
In parallel, the legal framework for the Swiss presence was established, including the incorporation of a Swiss entity and the definition of the target operating model. Particular attention was given to creating the required substance through the recruitment of qualified personnel and the establishment of suitable office premises, thereby ensuring compliance with Swiss tax, legal, and regulatory requirements.
In addition, all operational foundations were implemented, including the establishment of financial accounting in accordance with Swiss standards, the setup of a payroll system, and the preparation of employment contracts compliant with Swiss employment law.
Added value for the client
Through a structured approach, the market entry into Switzerland was implemented efficiently, in a legally compliant manner, and with appropriate tax considerations. The company was set up correctly from the outset from a legal, tax, and operational perspective.
The client benefited in particular from:
- a clear and robust structure for conducting business activities in Switzerland
- compliance with all relevant legal, tax, and regulatory requirements
- a fully functioning operational platform, including accounting and payroll processes in accordance with Swiss standards
- employment-law-compliant foundations for building up the workforce
- the utilization of tax benefits associated with the immigration step-up
- an expansion designed to be sustainable, compliant, and fit for long-term operations
