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1 Hosted by:
2
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4 More for less
5 General Facts
6 General Facts
7 Nobel Laureates per 10 Million Population Chocolate Consumption (kg/yr/capita)
8 Success Factors? Environment Connectivity Human Capital Taxation Cost Efficiency Quality of Life
9 Business Environment
10 Connectivity
11 Human Capital
12 Taxation
13 Taxation Corporate taxation Sustainability in financial policy Individual taxation St.GallenBodensee Ireland Netherlands UK Germany USA -20% -10% 0% 10% 20% 30% 40% 50% 60%
14 Taxation Federal relief
15 Taxation Federal relief
16 Taxation Federal relief
17 Cost Efficiency Monthly rent in CHF (willingness to pay) 1200 sq.ft. new flat Airport Zurich Airport Altenrhein
18 Cost Efficiency Illustrative Example 10 Staff 20 Lower Management 10 Senior Management 7 Saving potential of up to 1.0 mchf per year Region Senior Mgmt Lower Mgmt Staff 1) St.GallenBodenseeArea 100 % 100 % 100 % 2) Region Midland Switzerland 109 % 104 % 105 % 3) Northwestern Switzerland 124 % 123 % 110 % 4) Central Switzerland 111 % 109 % 104 % 5) Region Zurich 144 % 133% 106 % 6) Region Lake of Geneva 127 % 126 % 104 % 7) Tessin / Ticino 95 % 87 % 88 %
19 Cost Efficiency Example effective labor cost (in EUR) Germany St.GallenBodenseeArea Working days per year Days absent (sickness, holiday etc.) Effective working days Working hours per day Effective working hours per year 1'333 1'822 Hourly wage in EUR Hours to be paid 1'827 2'135 Annual wage in EUR 34'025 52'255 Non-wage costs: GER 45%, CH 29% 49'438 67'237 Effective costs per working hour in Euro
20 Quality of Life
21 St.GallenBodenseeArea Environment Connectivity Human Capital Taxation Cost Efficiency Quality of Life
22 120% Switzerland at 80% of the costs
23 120% Switzerland St.GallenBodenseeArea Your Business Location in Europe at 80% of the costs
24 Ready for takeoff? Franc Uffer Delegate / Director Foreign Direct Investment t franc.uffer@sgba.ch 24
25
26 DOING BUSINESS IN SWITZERLAND Going Global Initial Considerations Morris F. DeFeo Jr. Jennifer A. Ray September 15, 2015 Experience. Creativity. Results.
27 Practical Issues Internal/external resources and priorities Diligence, including compliance matters Reconciling legal norms and requirements Allocating risks Cultural and linguistic barriers Nature and style of agreements Specific issues with dealer, distribution and agency agreements Contractual interpretation issues Governing law Dispute resolution issues 1
28 Practical Issues (Cont d.) Protection of IP and other proprietary assets and rights Labor and employment law considerations Tax consequences 2
29 International Operational Risks Political and economic stability Effects of potential changes in government policies Change of government Change in governmental priorities General compliance obligations E.g., US FCPA, Export Controls, ITAR, money laundering Burden of compliance with local laws and legal requirements and potential for conflict 3
30 Tax considerations Earn income outside United States Often requires shift in assets or IP outside United States Consider outbound tax Defer U.S. tax on income until repatriated U.S. has one of the highest tax rates in the world Avoiding subpart F is critical 4
31 Tax considerations Integrate Switzerland tax law with U.S. tax consequences Determine whether treaty applies Dividend withholding generally reduced to 5% for 100% owned subsidiary. Interest withholding reduced to 0%. Maximize foreign tax credit May be beneficial to treat Swiss subsidiary as disregarded entity in certain circumstances 5
32 Example: Foreign IP Company Objective: defer U.S. tax on foreign sales until profit repatriated US Sales IP Sale IP Payment or costsharing buy in US Outside US US Parent Swiss Subsidiary Shift right to exploit foreign use of IP to a more favorable jurisdiction Possible to structure as sale, contribution, or cost sharing agreement. All three result in some amount of current tax to US Parent based on value of IP. Most effective for non-us sales IP profits taxable if repatriated to US Transfer pricing is critical Non- US Sales 32 6
33 A TRANSFER PRICING PERSPECTIVE By David Marion Thompson Greenspon
34 TRANSFER PRICING Why Switzerland? Key Considerations Favorable Tax Rates Hospitable Transfer Pricing Environment THOMPSON GREENSPON CPAS & ADVISORS PARTNERING FOR SUCCESS
35 TRANSFER PRICING In Many European & Asian Countries, It s a Dogfight for Profits Transfer Pricing enforcement is on the rise both in the U.S. and abroad. The Swiss Competent Authority are very well equipped to represent you at the negotiation table. THOMPSON GREENSPON CPAS & ADVISORS PARTNERING FOR SUCCESS
36 TRANSFER PRICING In a Transfer Pricing Controversy, the Swiss Most Often Side with the Resident Entity Low tax rates provide incentives for profits to reside in Switzerland. It is rare that a situation develops where an entity has erroneously shifted income out of Switzerland. THOMPSON GREENSPON CPAS & ADVISORS PARTNERING FOR SUCCESS
37 TRANSFER PRICING How Could Switzerland Be Even More Inviting from a Transfer Pricing Perspective? New OECD draft provisions (the Base Erosion and Profit Shifting project) have given even more incentives to aggressive taxing authorities worldwide in their quest for income recognition and expansion of their tax base. THOMPSON GREENSPON CPAS & ADVISORS PARTNERING FOR SUCCESS
38 TRANSFER PRICING Do I Really Need a Transfer Pricing Study? Significant Risks Exist if a Pricing Study is not conducted. Changes to your transfer price can result in additional penalties that can be quite severe. THOMPSON GREENSPON CPAS & ADVISORS PARTNERING FOR SUCCESS
39 TRANSFER PRICING The St. Gallen-Bodensee Area in Beautiful Switzerland A GREAT PLACE TO VISIT AND MAYBE MORE Like setting a transfer price! THOMPSON GREENSPON CPAS & ADVISORS PARTNERING FOR SUCCESS
40 DAVID MARION International Transfer Pricing Specialist 35+ Years with IRS 21+ Years in International Compliance -12+ Years Manager of Large International Examination Group 3+ Years Senior Manager of IFASP (International Field Assistance Specialization Program) -2 Years Senior Manager Foreign Payments Program (QI, Withholding, Penalties, etc) 5 Years Senior Manager in Competent Authority (Switzerland & France 4 years, all of Europe 3 years, & Canada 2 years) 2 nd Year with Thompson Greenspon THOMPSON GREENSPON CPAS & ADVISORS PARTNERING FOR SUCCESS
41
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