Swiss Taxation of Equity-Based Compensation Instruments – Part 2

The taxation of executive compensation is an important element in Switzerland’s international attractiveness. In this regard, equity-based compensation instruments are frequently used by multinational enterprises for their key employees. However, various complex Swiss tax issues arise both for the employer and the participants, in particular when participants of equity-based compensation schemes relocate and thus import or export their employee participations. In practice, it is advisable to obtain a Swiss tax ruling for the purpose of uniform tax assessment of the participants and proper tax treatment in intercantonal and international scenarios.