Switzerland: Business restructurings may result in exit taxes

Small changes in a taxpayer’s operating or business model can potentially result in an exit tax

Business restructurings may result in exit taxes

Even small changes in a taxpayer’s operating or business model can potentially trigger an exit tax liability in Switzerland, including:

  • A full restructuring, transferring the whole business from one jurisdiction to another
  • The relocation of employees across the organization
  • The relocation of an asset, such as tangible assets, IP, agreements or clientele
  • The transfer of an activity, through termination or substantial renegotiation of existing arrangements

To determine whether something of value has been transferred in connection with any restructuring (i.e., an asset (tangible or intangible) or an entire or a part of a business function) and would require compensation, it is essential to understand the restructuring and the changes in the internal processes and responsibilities by evaluating the function, asset and risk profile of the parties before and after the restructuring. In addition, compensation may be required as a result of conversion costs such as closure and restructuring costs, termination costs, and/or the loss of future earnings, such as with a shift in customer contracts.

Local tax specifics also need to be considered—such as the implication of any stamp duties, value added tax (VAT), registration tax, and withholding tax. There may also be registration or reporting requirements (i.e., DAC 6).

Read a February 2022 report prepared by the KPMG member firm in Switzerland


The KPMG name and logo are trademarks used under license by the independent member firms of the KPMG global organization. KPMG International Limited is a private English company limited by guarantee and does not provide services to clients. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 3712, 1801 K Street NW, Washington, DC 20006.