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Historically, Switzerland has mainly been used as a location where multinational enterprises where centralizing risks and functions in order to attribute high profit margins. This was the case because of the internationally comparatively low tax rates, in particular for companies enjoying special tax regimes, and the taxpayer-friendly approach taken by the tax authorities.

Luke Barlow

Sarah Dahinden

Carlos Baniqued

Robert Peake

Roman Blazhko

Thomas Chen

Shaun Austin

Last year at about this time, we boldly offered our predictions as to the outcomes multinationals could reasonably expect as a result of the efforts of the OECD and the unprecedented energy expended on its base erosion and profit shifting (BEPS) project. We were limited in our vision by the absence of the actual BEPS Action Plan, which was released two days after our publishing deadline. One of our predictions described how, perhaps from the perspective of unintended OECD consequences, countries like Ireland, Switzerland and Singapore could see their economies grow and unemployment dwindle. And they would quietly thank the OECD for its missionary-like zeal in chasing the no-economic-activity brass-plate companies out of places such as the Cayman Islands. If our vision had been just a little sharper last year, we would have added the UK to our shortlist of BEPS beneficiaries.

In re Puentes del Litoral the Argentine Supreme Court analysed whether, in a cross-border transaction agreed with grossing-up, the amount of the income tax assumed by the local party has to be considered for value added tax (VAT).