Special Situations
A position that needs to be assessed before it is acted on, negotiated with an authority, or brought back into order. These matters turn on facts and on cantonal practice, so we establish both before we advise.
Expenditure-based taxation is a cantonal matter, and cantons differ in both their thresholds and their willingness. We assess eligibility honestly — including the cases where it does not apply — prepare the application, and take it to the authority ourselves. We have handled more than twenty such cases across six cantons.
Eligibility assessment · Cantonal comparison · Application preparation · Engagement with the cantonal authority · Annual filings under the agreed basis
Where a treatment is material and uncertain, it can often be settled in advance rather than argued afterwards. We prepare the submission, present the facts as they are, and engage directly with the relevant authority. A ruling is granted at the authority's discretion; we do not promise one.
Feasibility assessment · Submission drafting · Authority engagement · Implementation and monitoring of the agreed treatment
Regularising a historic position is a procedure, not a negotiation. The work is in the reconstruction: years of records, valuations and income, assembled to the standard the canton requires. We prepare it and represent you through the procedure, with counsel where the matter calls for it.
Reconstruction of the historic position · Disclosure preparation · Representation through the procedure · Coordination with legal counsel · Return to ordinary annual compliance
Options, restricted shares and phantom plans designed elsewhere rarely land cleanly in Switzerland. We establish how a plan will be taxed here, at grant, vesting or exercise, and produce the reporting the employer owes on it.
Plan review for Swiss treatment · Valuation and reporting obligations · Employer certificates · Cross-border allocation for mobile employees
Accounting treatment for companies holding or transacting in digital assets, and their treatment in personal returns — including the line between private wealth management and professional trading, which is where most of the exposure sits.
Crypto bookkeeping and valuation · Company holdings and treasury · Personal declaration of digital assets · Private versus professional trading assessment
Where certainty requires verification, we verify. We check the facts, consult the relevant authority or a qualified specialist, and come back with an answer we can stand behind. That takes a day longer and saves years.
Yes. We have handled more than twenty lump-sum taxation cases across six Swiss cantons, from eligibility assessment through to the application and the engagement with the cantonal authority.
Yes. We reconstruct the historic position, prepare the disclosure to the requirements of the canton concerned, and represent you through the procedure, working with legal counsel where the matter requires it.
We prepare and submit ruling requests and engage directly with the relevant authority. A ruling is granted at the authority's discretion on the facts presented, so no outcome can be guaranteed in advance — and we will tell you when we think one is unlikely.
Yes, for companies holding or transacting in digital assets and for individuals declaring them, including the assessment of whether activity is private wealth management or professional trading.
No, and be careful of anyone who says they do. We engage directly with the relevant authorities where appropriate, and we know how each one works in practice. That is experience, not privilege.
The ordinary years either side of a special situation — filings, residence, succession.
Accounting, tax, payroll and corporate administration as a single Swiss file.
When the special situation is the arrival itself, and the order it needs to happen in.
You don't need to know exactly what you need. Describe the situation and we will tell you whether it is something we should handle, and what it would involve.
