In the context of Meta Octav as a Swiss based company helping clients set up company, trust, or foundation structures, we offer services related to a multi-jurisdiction tax approach which is often crucial, especially as clients increasingly operate across borders and face the complexities of international tax laws. This range of services ensures clients can minimize their global tax liabilities, optimize their structures for cross-border activities, and remain fully compliant with evolving international tax regulations. Given Switzerland’s strong international financial reputation and favorable tax policies, our services are positioned as a one-stop solution for clients looking for sophisticated tax strategies in a globalized business environment.

Here’s a detailed breakdown of the specialized services that we can provide in the area of multi-jurisdictional tax planning and optimization:

1. Cross-Border Tax Structuring and Optimization

• Global Tax Strategy and Planning: Helping clients design a global tax strategy that minimizes overall tax liabilities while ensuring compliance with local and international tax regulations. This includes advising on the optimal jurisdictions for structuring companies, trusts, or foundations in light of tax treaties and tax incentives.

• Entity Structuring for Tax Efficiency: Providing guidance on choosing the right legal structures (e.g., holding companies, joint ventures, subsidiaries, SPVs) across multiple jurisdictions to optimize tax outcomes. This involves assessing the client’s operational needs, risk profiles, and global expansion plans.

• Optimal Jurisdiction Selection: Advising on the selection of jurisdictions for the establishment of holding companies or investment structures based on tax rates, business incentives, intellectual property laws, and other key factors. For example, choosing Switzerland for holding companies, Luxembourg for fund structuring, or Singapore for tax-efficient trading activities.

2. Tax Treaty Planning and Utilization

• Utilizing Double Taxation Treaties (DTTs): Helping clients navigate Switzerland’s extensive network of Double Taxation Treaties (DTTs) with over 100 countries, advising on how to structure transactions to take advantage of reduced withholding taxes on dividends, interest, royalties, and capital gains.

• Tax Treaty Arbitrage: Advising on strategies that optimize the use of tax treaties between Switzerland and other countries to minimize tax leakage (e.g., through the use of intermediary jurisdictions that benefit from favorable treaties with both the source and residence countries).

• Withholding Tax Planning: Ensuring that withholding tax rates on cross-border payments (such as dividends, interest, and royalties) are minimized through strategic use of tax treaties, exemptions, and holding company structures.

3. Transfer Pricing and Compliance

• Transfer Pricing Documentation and Compliance: Assisting multinational clients in establishing and maintaining transfer pricing policies that comply with international guidelines (OECD guidelines) and local tax regulations. This includes drafting transfer pricing documentation for cross-border transactions between related entities to avoid transfer pricing adjustments and penalties.

• Transfer Pricing Structuring: Advising on structuring intercompany pricing arrangements (such as royalty payments, management fees, or cost-sharing arrangements) to ensure tax efficiency and minimize exposure to audits and disputes in multiple jurisdictions.

• Establishment of family offices, IP holding comAdvance Pricing Agreements (APAs): Helping clients negotiate APAs with tax authorities in different jurisdictions to establish agreed-upon transfer pricing methodologies and avoid future disputes or adjustments.panies, or management companies

4. International VAT & Indirect Tax Advisory

• Cross-Border VAT Structuring: Advising on VAT/GST implications for international trade and services, particularly in jurisdictions with different VAT regimes. This involves helping clients structure transactions in a way that minimizes VAT/GST costs, including using VAT groupings or exemptions.

• Global Indirect Tax Compliance: Helping clients navigate complex indirect tax rules across various jurisdictions, ensuring compliance with VAT, sales taxes, excise duties, and other indirect taxes in countries where they operate. This includes guidance on VAT registration, invoicing, and compliance with local rules.

• VAT Recovery: Assisting clients in recovering excess VAT paid in foreign jurisdictions through international VAT refund mechanisms, ensuring the proper documentation and filings are completed.

5. Cross-Border Estate & Inheritance Tax Planning

• Wealth Transfer Structuring: Offering comprehensive estate and inheritance planning services for individuals or families with cross-border interests. This includes advising on trusts, foundations, and wills to minimize estate taxes, ensure smooth wealth transfer, and protect assets in multiple jurisdictions.

• Legal support for purchase agreements, notary procMulti-Jurisdiction Inheritance Tax Optimization: Helping clients structure their assets across different jurisdictions to minimize inheritance tax liabilities, considering the rules in both the country of residence and the country of asset ownership. This may include setting up family offices or using international trust structures.esses, and Lex Koller compliance

• Cross-Border Succession Planning: Assisting clients in ensuring their succession plans are compliant with local inheritance laws in multiple jurisdictions, particularly when they have assets in countries with different inheritance laws (e.g., forced heirship laws).

6. Tax Efficient Investment Structuring

• Cross-Border Investment Vehicles: Advising on the creation of tax-efficient investment vehicles (e.g., funds, joint ventures, holding companies, trusts) to facilitate international investment, ensuring the structure is tax-optimal across jurisdictions.

• Private Equity and Venture Capital: Offering tax optimization services for clients looking to invest in international private equity or venture capital. This includes structuring the investments to minimize capital gains taxes, using holding companies in jurisdictions with favorable tax treaties or preferential tax regimes.

• Real Estate Investment Structuring: Providing advice on tax-efficient real estate investment structures, particularly for cross-border property holdings, to minimize property taxes, stamp duties, capital gains taxes, and inheritance tax in multiple jurisdictions.

7. Global Tax Reporting and Compliance

• FATCA & CRS Compliance: Assisting clients in complying with FATCA (Foreign Account Tax Compliance Act) and CRS (Common Reporting Standard) regulations, ensuring proper reporting of cross-border financial assets and transactions to tax authorities.

• International Tax Reporting: Helping clients comply with local and international tax reporting obligations, including Country-by-Country Reporting (CbCR), Form 5471 (US), and Form 8938 (US). This includes preparing the necessary filings to comply with Swiss, EU, US, and other countries’ tax authorities.

• Managing Tax Audits and Disputes: Providing services to handle cross-border tax audits, representing clients during audits by local tax authorities, and helping resolve any disputes related to international tax matters.

8. Cross-Border Corporate Tax Compliance and Planning

• Corporate Tax Compliance: Ensuring that multinational corporations comply with corporate income tax requirements in multiple jurisdictions. This includes preparing corporate tax filings, managing local tax payments, and structuring tax-efficient corporate financing and dividend repatriation strategies.

• Managing Tax Risks in Multiple Jurisdictions: Advising on managing tax risks related to different jurisdictions’ tax laws, including ensuring that operations are compliant with anti-avoidance provisions (such as CFC rules, substance over form rules) in each jurisdiction.

• Anti-Avoidance Rules & BEPS Compliance: Assisting with compliance related to BEPS (Base Erosion and Profit Shifting) guidelines, including minimum tax standards and economic substance requirements, and ensuring that clients do not run afoul of anti-avoidance provisions under international tax treaties.

9. Private Wealth Management and Tax Structuring

• Family Office Tax Structuring: Assisting family offices in managing and structuring cross-border private wealth, helping to set up tax-efficient holding structures, estate plans, and international investments to preserve and grow wealth across generations.

• Trust & Foundation Structuring for Wealth Preservation: Providing specialized advice on structuring international trusts and foundations for tax-efficient wealth preservation and succession planning. This includes ensuring compliance with the tax rules of the countries where the trust or foundation operates.

• Philanthropy and Charitable Giving: Advising on international charitable giving strategies, including the establishment of private charitable foundations, ensuring that they meet the tax-exempt criteria in multiple jurisdictions while optimizing tax deductions for the donor.

10. International Tax Risk Management and Dispute Resolution

• Tax Dispute Resolution: Assisting clients in resolving cross-border tax disputes with authorities in multiple jurisdictions, including negotiating settlements, challenging assessments, and representing clients in international tax tribunals.

• Tax Controversy Management: Offering guidance on managing tax controversies across jurisdictions, including managing and mitigating the risk of tax audits, penalties, and reputational damage.

11. Swiss-Specific Tax Incentives and Opportunities

• Swiss Holding Company Privileges: Advising on Switzerland’s tax privileges for holding companies, including participation exemptions and reduced tax rates on dividends and capital gains, making it an attractive jurisdiction for multinational companies.

• Swiss R&D Incentives: Assisting with tax incentives for research and development (R&D) activities, which are particularly beneficial for technology-focused multinational companies.

• Swiss Cantonal Tax Optimization: Helping clients select the optimal Swiss canton for tax purposes. Some cantons offer preferential tax rates for international businesses, and structuring the business accordingly can result in significant tax savings.