Tax Asset & Investment Management
Based on the market environment and regulatory requirements, investment and asset managers currently confront a multitude of challenges. The needs of clients are increasingly personalized, and competition is intensifying.
We understand developing tax optimized investments and structures are key success factors in the business sector. Our Deloitte FSI Tax team can assist you in handling your tax issues so as to ensure your clients the most efficient and compliant solutions.
Relevant core areas of our practice are the following:
- Over the past few years, we have added significant expertise in the Foreign Account Tax Compliance Act (FATCA) to our existing skills regarding the Qualified Intermediary (QI) program. With Switzerland committing itself to automatic exchange of information and the OECD Common Reporting Standard (OECD CRS), Deloitte will apply the technical interpretations and operational wisdom developed and honed for FATCA and QI. Deloitte offers asset managers technical, operational and technological leadership for the cross-border tax reporting regimes.
- The asset management industry also faces the incoming EU Financial Transaction Tax (FTT), levying fees on financial transactions relating to all types of financial instruments, including shares, bonds, units in collective investment schemes and derivative contracts, if one of the financial institutions is located in the EU.
- As a recognized leader in both tax and technology, Deloitte is uniquely qualified to assess and address all of the implications related to compliance with the tax transparency regimes and EU FTT. From analysis and remediation of existing systems to design and implementation of enterprise-wide concepts and practical procedures needed to identify relevant information our specialists keep Asset Managers one step ahead in this developing area of compliance and risk.
- In the wake of global Tax transparency the return on investment (ROI) after tax today is more in focus than ever. Recovering withholding tax incurred on investment income, therefore, is crucial for any investor. Deloitte has extensive experience in reclaiming Swiss Withholding Tax based on an applicable DTT for foreign resident UHNWIs invested in Swiss securities via very complex investment structures.
- Another core topic is Swiss tax reporting for foreign funds. Deloitte acquired extensive experience in assisting foreign fund managers in determining the taxable income per share for Swiss resident individuals invested in their fund vehicles, including written confirmation through rulings with the Swiss Federal Tax Administration.
- Based on the Aberdeen Case ruled in 2009 by the European Court of Justice (ECJ) EU Investment Funds have the possibility to reclaim EU withholding tax incurred on underlying investments based on EU law. The Santander Case ruled by the ECJ in 2012 opened this opportunity for Non-EU investment funds. From managing the document and data collection to the labor intensive data reconciliation and data validation and to the preparation of the reclaim filings with the relevant EU Tax Authorities, Deloitte is uniquely qualified to support Asset Managers globally in reclaiming EU Withholding Tax with its dedicated cross-border and cross-service line team.