Tax services for financial institutions

We assist financial institutions with all aspects of tax compliance, including Swiss corporate income tax, withholding tax, VAT, stamp taxes and other Swiss taxes, from the preparation of the tax return to the dealings with the tax authorities. 

We leverage from technology, in particular KPMG’s Digital Gateway, to streamline the tax compliance process.

We assist with the complex tax challenges in today’s financial services environment, providing pragmatic solutions that meet legal and regulatory requirements and industry best practice.

This includes

• Mergers & acquisitions (tax due diligence)
• Structuring / restructuring
• Tax audits
• Tax rulings / tax opinions
• Health checks
• Tax accounting
• Tax classifications of financial instruments using our "Automated Tax Sections" technology - see our video for more information
• Tax suitability analysis of investment products (Tax Guides)
• Tax risk assessments / tax risk management
• Transfer pricing support
• Ongoing tax hotline
• Tax treatment of digital assets (blockchain / crypto / Distributed Ledger Technology (DLT))
  

Our team possesses many years of experience in assisting Swiss and international clients with all aspects of the U.S. Qualified Intermediary ("QI"), Foreign Account Tax Compliance Act ("FATCA"), Automatic Exchange of Tax Information (“AEOI”) and Crypto-Asset Reporting Framework (“CARF”) regimes, as well as all other operational taxes. In particular, we provide:

• Ongoing compliance support
• Reporting support, using KPMG’s AEOI Reporting tool
• QI/FATCA periodic reviews
• Responsible Officer certification support (see our latest survey results here)
• Health checks
• Policy documents & client onboarding forms
• Risk control frameworks
• Flowcharts and checklists
• Trainings tailored to the specific needs of your organization
• Withholding tax / stamp tax / transaction tax support

We assist asset managers and pension funds with a broad range of tax services, including:

• Swiss investor tax reporting (see our flyer)
• Fund structuring / re-structuring
• Global Compliance Management Services
• Investment reviews / tax due diligences
• Swiss and foreign withholding tax reclaims
• Swiss stamp tax analysis
• VAT analysis
• Transfer pricing support

Our Tax Litigation team assists clients in resolving complex tax disputes across all stages of controversy, from pre-litigation phases to representation before tax authorities and courts. Combining deep legal expertise with strategic negotiation and procedural experience, we protect our clients’ financial and reputational interests in a rapidly evolving tax environment.

We represent financial institutions in matters involving direct taxes, indirect taxes, transfer pricing, withholding taxes, stamp taxes and cross-border structures. 

Our services include:

• Representation in audits, reassessments, and administrative appeals
• Negotiation and settlement of disputes with tax administrations
• Litigation before cantonal and federal tax courts and the Federal Supreme Court
• Mutual agreement procedures (MAP) and international arbitration under tax treaties
• Coordination of tax disputes across jurisdictions

KPMG Switzerland offers a successful tax compliance technology called “Multishore Tax Reporting” (MTR), which provides an easy and efficient solution to produce automated tax reports for Swiss and international clients of Swiss banks.

> Learn more about Multishore Tax Reporting

We assist financial institutions with all transfer pricing aspects. Our dedicated Financial Services Transfer Pricing experts will help you to review your transfer pricing setup and to identify risks and opportunities related to the specific intra-group transactions in the financial industry. We can support you in planning sustainable and pragmatic transfer pricing systems adequately to your business needs. Finally, we can also support compliance and manage controversy cases (tax audits, Advance Pricing Agreements between tax authorities, rulings, etc.). 

> Learn more about Transfer Pricing Services

We assist financial institutions to understand the tax impact of the implementation of Profit Allocation and Nexus rules (Pillar 1), and Global Minimum Taxation (Pillar 2).

We provide insights into the key challenges which arise with the introduction of BEPS 2.0 and find clear answers to the questions raised by the model rules. In particular, we can offer:

• Tax technical advice
• Workshops
• Impact assessments and gap analysis
• Process definition and structuring
• Project implementation & Pillar 2 compliance support, leveraging from KPMG’s BEPS 2.0 Automation Technology tool (KBAT)
• Trainings

> Learn more about BEPS 2.0

We support companies in the financial services sector with the tax-efficient and tax-compliant execution of their transactions and business activities related to DLT and blockchain technologies. Our services include amongst others:

• Clarifying the correct VAT treatment and data requirements for all banking services around digital assets (wallet services, custody, trading, staking etc.)
• Supporting the issuance of tokens (Profit tax, Withholding tax, Stamp transfer tax, VAT)
• Assisting with the qualification of tokens for Swiss tax purposes 
• Assessing whether transactions involving digital assets are subject to Stamp transfer tax or Withholding tax
• Providing solutions around digital assets / transactions tax reporting & account statements
• Evaluating the tax treatment of investments in crypto assets by individuals
• Providing support regarding the readiness for information exchanges on digital assets 
• Providing tax advice with establishing crypto funds

> Learn more about the topic of DLT or our services in this area