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In tax matters, our firm is regularly involved in demanding assignments as can be seen from the following examples:

  • Advising of banks and borrowers regarding syndicate loans: We regularly advise banks and borrowers concerning the tax structuring of national and international syndicated loans. This involves complex tax questions, in particular in terms of withholding taxes, which typically have to be addressed under time pressure. By way of example, we assisted France Telecom SA in the "staple financing" for the purchase of Orange Switzerland by Apax Partners and we advised the syndicate banks in the financing of the takeover of Sunrise by CVC.
  • Swiss Confederation: In 2008, we advised the Swiss Confederation on the recapitalisation of UBS via a CHF 6 billion mandatory convertible bond. This was followed in 2009 by advising the Swiss Confederation on the placement of the UBS shares created by the conversion. This capital market transaction, by far the largest in Switzerland in 2009, was carried out using a combination of mandatory convertible bonds, private placements and cash transfers. It also lead to a series of complex questions on Swiss tax law.
  • Management of sportsmen and sports associations: For years, top-level Swiss sportsmen and international sports associations have placed their faith in the expert advice of Niederer Kraft Frey in tax matters.

We play a decisive role in shaping the legal and fiscal framework conditions for a series of important international sport events. In this context, we advise our clients concerning the tendering, tax assessment and conclusion of global marketing and advertising agreements. Our international work has given us a reputation as the ideal partner for the coordination, instruction and supervision of local tax advisors.

We also have extensive experience in the negotiations with foreign tax and other authorities which is of prime importance for the organisation of international sport events.

As part of our advising of top-level Swiss sportsmen, we appraise the contractual relations with sponsors and find beneficial solutions from a tax perspective. Additionally, we advise international sports personalities with tax liabilities in various jurisdictions concerning their global tax planning and optimisation.