Adapt your SAP authorisation concept to S/4HANA

S/4HANA is SAP’s next-generation business suite that is built on SAP’s proprietary operational database system and in-memory computing platform called SAP HANA. S/4HANA is intended to be easier to use and administer while helping to solve more complex problems and handle vastly larger amounts of data than ist predecessors. S/4HANA is available in on-premises, cloud and hybrid deployment models.

With the release of S/4HANA SAP consolidates the integration and harmonisation of functionalities and processes and further reduces barriers between SAP modules facilitating system integration. New technologies, such as Fiori, enhance the user interface for both desktop and mobile devices. The in-memory HANA database lets you collect, store, and process high volumes of operational and transactional data in real time.

Implementation of S/4HANA will affect your current environment, and not just technologywise because processes are also subject to change. Both – the new technology and the change in processes – will result in new requirements for your current authorisation concept. Whereas parts of your existing authorisation concept can be easily transformed and implemented 1:1 in the SAP S/4 HANA system, other parts need to be changed and adapted to meet the new requirements.

PwC has a proven track record in Switzerland and globally in implementing and transforming SAP authorisation models in the SAP S/4HANA environment. Our GRC Technology Team in Switzerland led and executed the authorisation implementation part of the ninth S4/HANA implementation worldwide from the authorisation concept, to implementation and operation. Our experts have the required skill-set, tools, techniques and experience to discuss your challenges with you, and to actively support you throughout the whole project.

Download the PDF by clicking the image below:

Please contact our team for more details:

Dominik Götz
Senior Manager
+41 58 792 28 93

Erik Trouillet
+41 58 792 23 64

EUDTG Newsletter January – February 2017

EU direct tax law is a fast developing area. This presents taxpayers, in particular groups and multinational corporations that have an EU or European Economic Area (EEA) presence, with various challenges.

The following topics are covered in this issue of EU Tax News:

CJEU Cases

  • Netherlands: CJEU judgment on pro-rata personal deductions for non-resident taxpayers: X
  • Netherlands:  CJEU judgment on the application of Article 64 (1) TFEU concerning the extended recovery period for foreign assets: X

    National Developments
  • Belgium: New Innovation Income Deduction replaces the Patent Income Deduction
  • Finland: Supreme Administrative Court confirms withholding tax treatment for non-UCITS and non-listed Maltese SICAV
  • Hungary:  Hungarian implementation of ATAD’s CFC rules
  • Italy: Italian Tax Court of First Instance judgment on the compatibility of withholding tax levied on dividends distributed to a US pension fund with EU law
  • Sweden: Swedish Supreme Administrative Court judgments on the denial of refund of Swedish withholding tax
  • Switzerland: Corporate Tax Reform III rejected by the Swiss voters
  • United Kingdom: Supreme Court judgment in R (on the application of Miller and another) v Secretary of State for Exiting the European Union

EU Developments

  • EU: ECOFIN Council agreement on ATAD II
  • EU: European Parliament Resolution of 14 February 2017 on the annual report on EU competition policy
  • EU: Public CBCR: European Parliament’s joint ECON & JURI Committee issues draft report
  • EU: EU Member States send letter to non-EU 92 countries in context of common EU list of non-cooperative tax jurisdictions
  • Spain European Commission requests Spain to amend its law implementing reporting obligations for certain assets located outside of Spain

Fiscal State aid

  • Luxembourg: Non-confidential version of the European Commission’s State aid opening decision in GDF Suez
  • Spain: AG Opinion on tax exemptions for Church-run schools

Read the full newsletter here.

This EU Tax Newsletter is prepared by members of PwC’s international EU Direct Tax Group (EUDTG).

Further information about our service offerings in EU taxes:

Legal certainty concerning import value in Switzerland reestablished – Assessment of 100 million swiftly overruled by the Federal Supreme Court

In understanding of the business impacts, the Federal Supreme Court clarified the uncertainty on determination of the import VAT value for foreign companies involved in supplies of goods to Switzerland resulting from the recent decision of the Federal Administrative Court.
Click here to download the PDF


A., a purchasing company of C. group established outside of Switzerland, however registered for Swiss VAT purposes, was acquiring goods from foreign third party suppliers. The goods were shipped to a Swiss warehouse of A. from where those were subsequently sold to C. (a Swiss established and VAT registered distribution company of the C. group), or other third party customers.

For customs clearance, the import value of the goods declared by A. was based on the price invoiced by the foreign suppliers to A. (i.e. on the purchase price). Further to their investigation, the Swiss Federal Customs Authorities (“SFCA”) claimed that A. underestimated the import VAT base, which should have been the sales price to C. minus 10%.
Click here to download the PDF
In the first instance, the Federal Administrative Court (“FAC”) also denied determination of the import VAT value of the goods based on the price paid by the (foreign) importer to its foreign suppliers and supported the post-assessment of the SFCA of 100 mio CHF import VAT and almost 1 mio late interests. The position of the Court was held on slightly different grounds than the one of SFCA. The FAC ruled that (i) the transaction with foreign suppliers occurred already abroad as the importer had the power to dispose of the goods abroad since he was in charge of the transport of goods to Switzerland and therefore the purchase price paid by A. should not have been determinant for the import value, and (ii) it should have then been the market value, which however in the view of FAC corresponded to the value paid by the final Swiss customer to third party suppliers minus 10%. Thus in practice, FAC actually accepted for the case at hand that the value should have been the sales price to C. minus 10%, which was the original position of SFCA.

Decision of the Federal Supreme Court

The Federal Supreme Court (“FSC”) overruled in its decision 2C_1079/2016 issued on 7. March 2017, the decision of the FAC. In this surprisingly short period after the first instance decision, FSC held that the transaction relevant for the determination of the import VAT value is the transaction which led to the import, i.e. the price paid by A. to its foreign suppliers and clearly not the market value related to the subsequent transaction with C, as at the moment of the import the contract with the final customer was not yet in place.

Click here to download the PDF

The FSC ruled that the fact who is the person in charge of the transport (i.e. supplier v. importer) has no impact on identifying the transaction relevant to determine the import VAT value of goods. Indeed, the FSC considered that the import value should be based on the agreement which gave rise to the transaction leading to import and that the transport is only a modality of the execution of the agreement.

The Court also considered that the characteristic feature of the purchase was the acquisition of goods abroad intended for sale in Switzerland and therefore the final destination was already known at the time of purchase from A to their suppliers. Consequently, based on article 54, al.1, let. a of the Swiss VAT law which provides that import value is the consideration where goods are imported under sales or commission agreement (and not the market value), the Court ruled that such consideration is the purchase price paid by A. to its foreign suppliers.

This decision removes the uncertainty resulting from the previous position of Customs Authorities in this case and following decision of the FAC, and confirms our standpoint on this subject matter. Fortunately, the Federal Supreme Court brought back the clarity into operations of many businesses, which is not only in line with the Swiss VAT law but also with the international standards. The FSC decision removes a certain inequality between foreign and Swiss based importers and gives necessary comfort to (foreign) companies involved in similar supply chain scenarios for the purpose of their customs reporting obligations. Companies importing goods in Switzerland for further sale via their local stock should ensure that their reporting is in line with this final decision of the FSC. The federal customs, as well as tax authorities will now need to review their practice and amend written guidelines in order to align with the legal grounds.

Download the PDF by clicking the image below:
Click here to download the PDF


Please contact our team for more details:
Patricia More, Partner, Indirect Tax, PwC Geneva / +41 58 792 95 07

Christina Haas Bruni, Senior Manager Customs & VAT, PwC Basel / +41 58 792 51 24

Kristyna Kaniova, Manager, Indirect Tax, PwC Geneva / +41 58 792 92 34

Hans-Frederic Andersen, Senior Consultant, Indirect Tax, PwC Geneva / +41 58 792 91 97

QI renewal deadline is fast approaching (31 March) and IRS publishes new FAQs regarding QDD application

QI Renewal Deadline

Qualified Intermediaries (QIs) that wish to renew their QI Agreements with an effective date of 1 January 2017 are reminded that the application for their renewal is due by 31 March 2017.  Renewing by 31 March 2017 will ensure that there is a seamless transition from the old QI agreement to the new 2017 QI Agreement.

The application must be submitted online through the new IRS QI Portal.

For more information about the application process and the use of the portal, please see our PwC Tax Insights publication.

New FAQs regarding QDD application

On 17 March 2017, the IRS published new Frequently Asked Questions (“FAQs”) that provide additional details regarding the completion of the application questions for QIs that wish to apply to be Qualified Derivative Dealers (“QDDs”) for 2017.  These FAQs are published on the FATCA FAQ website under the Qualified Intermediary heading.  There are a total of eleven FAQs (beginning with #10) posted by the IRS that answer a variety of questions regarding the completion of the application for QDD status.

QI’s that wish to be QDDs with an effective date of 1 January 2017 must submit their applications on or before 31 March 2017 through the online QI Portal.

SuisseTax Online Portal Open for AEOI Registration

As of this week, ESTV SuisseTax, the Swiss Federal Tax Administration’s online portal, has opened its AEOI registration function for reporting Swiss Financial Institutions (“FIs”). Reporting Swiss FIs must register by the end of 2017 for an initial AEOI data exchange in 2018.

Please note that a registration for AEOI purposes is only possible via the online portal. Swiss FIs can enter the ESTV SuisseTax portal by referring to the following link:

The Swiss Federal Tax Administration is expecting to provide a data exchange test phase for reporting Swiss FIs in the summer of 2017.

Please refer to the link below for the official media release:

Changes to legislation governing Swiss VAT liability

Swiss VAT law places new obligations on foreign companies

The partial amendment to the Federal Law on Value Added Tax (VAT law) will impact companies not established in Switzerland from 1 January 2018. Businesses which are not based in Switzerland but provide supplies vis-a-vis Switzerland may be liable to pay Swiss VAT. This will apply in instances where a foreign company generates turnover in Switzerland, in other words in cases where Switzerland is the place of supply for the purposes of VAT. The following information outlines the VAT situation in Switzerland today and in the near future.

Download the full report here.

If you have any questions, please get in touch your usual PwC contact person or our expert

Julia Sailer
Leader VAT compliance Switzerland
Tel. +41 58 792 44 57

Additional Languages for this report


Business Review of Premier Li Keqiang’s Government Work Report 2017

March 2017

China recently held the 12th National People’s Congress in Beijing. Premier Li Keqiang announced a number of key policies and initiatives which sets the country’s economic direction. These changes will have profound implications on the business landscape in 2017 and beyond. As part of the Congress, Chinese Premier Li Keqiang delivered the Government Work Report which provides a review of:

I.   Government’s achievements in 2016;
II.  Government’s goals and priorities for 2017; and
III. Government’s plans and actions to improve quality and effectiveness of growth.

Key highlights of the Report

Economic growth rate

  • GDP growth rate for the coming year has been set realistically at “around 6.5%, or higher if possible in practice,” relative to the range of 6.5-7% for 2016.

Fixed and private investments

  • The government will invest 800 billion yuan in railway construction and 1.8 trillion yuan in highway and waterway projects in 2017 while continuing its massive investments in major state projects.
  • To encourage growth in private investments, the government plans to improve policies as well as public administration and promote Public Private Partnerships.

Emerging industries and investment hot-spots

  • The government plans to accelerate the R&D and commercialisation of new materials, artificial intelligence, integrated circuits, and bio-pharmacy and 5-G mobile communications.
  • The government has also set aggressive targets for environmental protection and plans to launch extensive ‘Fitness-for-All’ initiatives, creating business opportunities in education, elderly care, healthcare, tourism, e-commerce and creative services.

Pro-business reforms

  • The government plans to make service industries, manufacturing, and mining more open to foreign-invested firms (FIEs).
  • There are also plans to treat FIEs the same as domestic firms on applications, standards-setting and government procurement and allowing FIEs to enjoy the same preferential policies under the Made in China 2025 initiative.

Real estate sector

  • In 2017, the government will establish robust long-term mechanisms to promote steady and sound development of the real estate sector to restrict further investment and “speculative” purchases by residents and investors.

RMB exchange rate and bad debt

  • To address the rising non-performing loans, Premier Li has pledged to reform the financial regulatory system and work systematically to defuse major potential risks.

Leap ahead: 2016 China tax policy review and 2017 outlook

China Tax Policy Review and Outlook is a series of PwC China Tax annual publication designed to review key tax policy developments in China and discuss the trends and impacts to Chinese businesses from a forward-looking perspective. This 2016 China Tax Policy Review and 2017 Outlook is the second issue in the series.

2016 was a year of transition for China. It was also the first year of the 13th Five-Year Plan. The State Administration of Taxation has released a series of tax policies to support the transition of China’s economy. Turning eyes to the international taxation, China has voiced out her stance on international collaboration to foster growth, innovation and transparency, and her goal to establish a modern tax administrative system by 2020.

Highlights of the 2016 China Tax Policy Review and 2017 Outlook: 

  • Impact of the Business Tax to Value-added Tax Transformation Reform and outlook of the next phase of VAT reform
  • Innovation-driven tax incentives related to High-New Technology Enterprises, equity incentive plans, etc. and “green tax” initiatives (Resource Tax and Environmental Protection Tax)
  • Development of tax transparency (e.g. Country-by-Country Report and Common Reporting Standard) echoed by China’s digital administrative strategy (“Golden Tax III” and “Thousand Groups Project”) New trend of tax dispute resolution mechanism (e.g. tax administrative appeal and court litigation, Advance Pricing Arrangement, Mutual Agreement Procedure)
  • Key words for 2017 outlook, e.g. anti-tax avoidance, localisation of BEPS recommendations, details of Environmental Protection Tax Law, further cut in tax and government levies

With China’s increasing influence on the global economy and international taxation, we have more to expect in the years to come. As Mr. Wang Jun, the SAT Commissioner, commented, “The SAT will step up effort in 2017 to balance its focus on inbound and outbound taxation, and refine some of the existing rules to add more certainty and clarity.” Policies in the 2017 pipeline may include revised anti-avoidance rules related to Controlled Foreign Corporations, Thin Capitalization, etc.; rules to further implement the BEPS project recommendations regarding anti-treaty abuse; landmark reforms in terms of Individual Income Tax, Property Tax; the elaboration on the implementation of the Environmental Protection Tax Law; further cut in non-tax government levies; and what taxpayers are most earnestly waiting for, the new look of the Tax Collection and Administration Law.

Download the full report here.


Digital goes live – Meet PwC at the SAP Forum 2017 – Switzerland’s biggest digital festival

Visit us at the SAP Forum 2017, Switzerland’s biggest SAP event, in Basel on 4–5 April. Spend two fascinating days with technical specialists and industry experts and make the most of the discussions about current trends in digital transformation with SAP.

PwC and SAP enjoy a long-standing, global partnership. With 7,500 PwC experts worldwide, we support our customers from the strategy stage through to implementation in SAP transformation projects. PwC was named as a leader in the Gartner Magic Quadrant for SAP Implementation Services in 2015 and was also recognised in the IDC MarketScape Worldwide SAP Implementation Services Ecosystem Vendor Assessment in 2016.

We look forward to discussing any challenges that you might be facing in relation to SAP, SAP HANA and process and technological support for value-added tax, customs clearance, security and compliance with SAP.


Congress Center in Basel. You can find us in the second floor foyer.

Highlights from the programme:

Tuesday 4 April 2017 – Business Summit – primarily aimed at business decision-makers

Inspiring keynote speech by Skype founder Jonas Kjellberg

Creative approaches: Forward thinkers present digital business cases live on stage, including

  • SBB’s reporting strategy as a marker of innovation
  • OC Oerlikon’s commitment to digital transformation in its procurement, finance and shared services areas
  • Adrian Zwingli, founder of SwissQ, talks about the changes to the company’s structure
  • Nicole Burth Tschudi, CEO of Adecco Schweiz, presents her vision for the working world of the future

An opportunity to experience digital innovation topics through exciting showcases

‘Elevator pitches’ on SAP S/4HANA, the cloud and security

Forging strong alliances: the open programme and lots of lounge areas provide just the right environment for making new contacts.

Wednesday 5 April 2017  – Technical Summit – primarily aimed at decision-makers and experts from the technology sectors

SAP Executive keynote speech by Rolf Schumann, Global General Manager for Platform and Innovation | SAP Cloud Platform

Drawing upon practical experience – fascinating insights into current digital transformation projects:

IoT Live! – AMAG launches is digital fleet

  • Success with SAP S/4HANA! From making the initial decision to going live: reporting to customers
  • Implementing an international, multilingual B2C shop based on SAP Hybris, presented by Mammut
  • S/4HANA enterprise management @ BKW – one of the first to go live in Switzerland!
  • Landscape transformation and system conversion at Zurich Insurance

The key trends of machine learning and mixed reality, plus interactive deep-dive sessions

48-hour SAP InnoJam session: the ultimate coding challenge goes into the next round!


Put together your own personal programme here.


The ‘SAP Forum 2017’ event is directly organised by SAP (Switzerland) AG. PwC is involved in the event as a supporting partner. Please register directly via the following link at SAP (Switzerland) AG. Participation in the event is free of charge for those who have registered in advance. A walk-in fee of CHF 150 (excluding VAT) is charged for those attending without having registered previously. Please note the registration rules on the event website.

You can contact us in person at any time.

Jozsef Csoka
Senior Manager Advisory
+41 58 792 75 16

Intensive Course on IFRS

June 2017
Courtyard by Marriott, Zurich


Does your company report in accordance with International Financial Reporting Standards (IFRS), or are you responsible for preparing the financial statements in compliance with IFRS? Is your company considering a move to IFRS? Or do you simply want to extend or to refresh your IFRS expertise? Then PwC’s intensive course on IFRS is right for you.


Our module based IFRS course will help you deal with IFRS professionally and apply the standards competently by giving you:

  • a solid basic understanding of the most important IFRS/IAS standards and of recent developments
  • detailed knowledge of the content of these standards and how they are applied.

You will learn how IFRS facilitates transparent external reporting. But you will also find out how to use it as a helpful instrument that supports you in assessing the financial position of your company and in recognising priorities. The course shows you how to put the theory into practice.

Methodology and organisation

All modules are specially designed for finance specialists and users of IFRS. In class you have presentations, group work, case studies and sharing sessions to expand and apply what you have learned.

Although all participants are invited to join all 5 modules, please keep the following in mind while registering: on day 4 we will look at IFRS 15 and IFRS 9 from the viewpoint of corporate entities. On day 5 we will tailor the discussion for the needs of the financial services industry, with a focus on IFRS 9.

Date and location:
The course will be held in five modules, each lasting one day from 8:30 am to approx. 6 pm in English.

Module 1: Tuesday, 13 June 2017
Module 2: Wednesday, 14 June 2017
Module 3: Monday, 19 June 2017
Module 4: Tuesday, 20 June 2017
Module 5: Wednesday, 21 June 2017

Courtyard by Marriott
Max-Bill-Platz 19, CH-8050 Zurich

1 module:     CHF 1,300 including VAT
2 modules:   CHF 2,500 including VAT
3 modules:   CHF 3,600 including VAT
4 modules:   CHF 4,500 including VAT
5 modules:   CHF 5,400 including VAT

This includes course documentation, refreshments (breaks and lunch) and parking.

Please register online.


For more information click here.