Group taxation

Companies

Generally, a corporate group is created through the expansion or diversification of its activities, as well as through mergers and acquisitions.

Too often, the tax issues of a corporate group only appear when it becomes necessary to restructure it or to separate from a division. These issues then become a hindrance to the sale operation, or even prevent the sale ("deal breaker"). This happens in cases where the buyer considers that the tax risks are too important or uncertain. A tax problem usually has to wait several months to be solved. It is highly possible that during this period the economic conditions have changed dramatically, so that even if the tax problem is now solved, the buyer is no longer in favor of a purchase transaction. Such a disaster scenario is one that every entrepreneur would like to avoid.

Group taxation consists of a detailed analysis of the activities of each company, their balance sheet, their results, the projects linked to these companies and the general philosophy of the group. It is a question of studying whether by common means (transfer pricing management for example) or other more complicated ones (restructuring, refinancing, cash pooling, dividend remittance, personnel management, VAT, etc.), substantial tax savings can be achieved, now or in the longer term. This is all the more true in case of sale or separation of a division. Each underlying tax risk is analyzed, quantified and solutions to resolve it are provided. The resolution of the risk is done in stages, in a timely manner.

Group taxation also includes issues related to inter-cantonal groups and problems of profit and capital distribution, which can also lead to significant tax savings.

Our global, individual and personalized approach allows us to propose adapted solutions, which are in line with the economic decisions, respect the tax norms, optimize the global tax burden of the group and limit the future tax risks, particularly in case of division sales, management buy-out or company transfers.