Switzerland as a location for the tax planning of international corporations (inbound)

Case 1a Financing

SwissCo is mainly financed with an interest-free loan from its Irish sister company
Loan portfolio managed by employees of SwissCo
Loans exclusively to non-Swiss
Group companies (OpCos)

SwissCo acts as principal and is the beneficial owner of all non-US intellectual property rights (trademarks and distribution rights) with the exception of those for product X, which are held by US IPCo
SwissCo sells goods to related distribution companies in the UK and Germany and grants them the necessary rights for local marketing / distribution via licenses
Foreign distribution companies pay purchase price and licence fees to SwissCo
SwissCo also pays annual royalties to US IPCo in connection with the marketing/distribution of product X

Tax assessment in Switzerland
Assessment in an international context (UK, D and US)
Possible tax measures and consequences in Switzerland under consideration of SV-17

SwissCo is the beneficial owner of intellectual property rights and, as Master Distributor (MD), coordinates the distribution of software (physically) in Europe via related local distribution companies (sales commission agents)
SwissCo records all trading sales and collects the residual profit in Switzerland
SwissCo has no staff in Switzerland and performs its functions via UKCo, whose services SwissCo remunerates on a cost-plus basis
Software development takes place in US and UK
Group considers transferring MD functions from SwissCo to UKCo
Alternative: In addition to MD functions, intellectual property rights including Cost Share Agreement (CSA) are also transferred to UKCo