Corporate Tax 2019

Author:Ms Susanne Schreiber, Corinna Seiler and Elena Kumashova
Profession:Baer & Karrer

Overview of corporate tax work over last year

Types of corporate tax work


The amount of outbound and inbound M&A transactions continued to grow in 2018. The record-breaking 493 transactions involving Swiss companies and investors were reported with a transaction value amounting to USD 132.9bn. 2018 also saw an increasing number of transactions involving private equity funds, with the deal value increasing by 97%. The key transactions include the sale by ABB Ltd of its power grids business to Hitachi for USD 11bn and the acquisition by Worldline SA of SIX Payment Services for USD 2.9bn as part of their cooperation strategy. On the private equity side, the acquisition by Partners Group (Zug) together with Caisse de depot et placement du Quebec (Quebec City) and Ontario Teachers' Pension Plan (Toronto) of the German Techem for USD 5.4bn stands out.1 For the current year, it is assumed that M&A activity will remain strong.

Tax litigation

In 2018, a large number of cases regarding international requests for administrative assistance have been judged by the Swiss Federal Supreme Court. The Federal Supreme Court will only hear administrative assistance cases if the legal question to be decided is of fundamental importance. The fact that the Supreme Court decided 10 administrative assistance cases out of 20 in 2018 despite the restricted access shows that there are many outstanding, mostly procedural questions to be clarified in the field of administrative assistance. In September 2018, the Federal Tax Administration (FTA) transmitted bank account details to its Automatic Exchange of Information (AEOI) partner states for the first time. Hence, we expect a considerable amount of tax litigation work regarding AEOI in 2019.


During 2018, 12...

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