Don’t be caught out by DAC6

The EU is introducing radical measures to tackle tax abuse and ensure fairer taxation by increasing the level of transparency another notch in order to detect potentially aggressive tax arrangements.

The amendment to Directive 2011/16/EU on administrative cooperation in the field of taxation (DAC6 for short) will have far-reaching consequences for tax advisors, service providers and taxpayers – including organisations and individuals in Switzerland.

DAC6 imposes mandatory disclosure requirements for arrangements with an EU cross-border element where the arrangements fall within certain “hallmarks” mentioned in the directive and in certain instances where the main or expected benefit of the arrangement is a tax advantage. There will be a mandatory automatic exchange of information on such reportable cross-border schemes via the Common Communication Network (CCN) which will be set-up by the EU.

Although the directive is not effective until 1 July 2020, taxpayers and intermediaries need to monitor their cross-border arrangements already as of May 2018. Therefore the time to act is now.

DAC6 in a nutshell

Who? Intermediaries such as tax advisors, accountants, banks and lawyers, who design, market, organise, make available for implementation or manage the implementation of potentially aggressive tax-planning schemes with an EU cross-border element for their clients as well as those who provide assistance and advice

What? Mandatory reporting by tax intermediaries (or taxpayers) and the automatic exchange of information by the tax authorities of EU member states via the Common Communication Network (CCN) for a wide range of cross-border arrangements in relation to individuals and entities.

Why? The main purpose of DAC6 is to strengthen tax transparency and fight against aggressive tax planning. It broadly reflects the elements of action 12 of the BEPS project on the mandatory disclosure of potentially aggressive tax-planning arrangements.

How? The potentially aggressive tax planning arrangements with a cross-border element need to be reported by the intermediaries to the tax authorities in the country in which they are resident. The EU member states then will share the information with all other member states via the Common Communication Network (CCN) on a quarterly basis.
If the taxpayer develops the arrangement in-house, or is advised by a non-EU adviser, or if legal professional privilege applies, the taxpayer must notify the tax authorities directly.

Penalties will be imposed on intermediaries that do not comply with the transparency measures. EU member states to implement effective, proportionate and dissuasive penalties.

Find out more about DAC6 and if you are affected online and get in contact with our experts.

Contacts

Monica Cohen-Dumani
Partner
+41 58 792 97 18
monica.cohen.dumani@ch.pwc.com

Bruno Hollenstein
Partner
+41 58 792 43 72
bruno.hollenstein@ch.pwc.com

Australia lowers Managed Investment Trusts (MITs) withholding tax for Swiss investors

Current Situation

Swiss investors currently investing into Australian Managed Investment Trusts (MITs) have not been able to benefit from the reduced 15% withholding tax rate despite Switzerland having implemented the automatic exchange of information with Australia, the reason was that the Australian government had not updated the list of eligible countries yet.

Update of list of countries with beneficial withholding tax rates

The Australian government has now announced that it will update the list of countries whose residents are eligible to access a reduced withholding tax rate of 15 per cent, instead of the default rate of 30 per cent, on certain distributions from Australian MITs. Listed countries are those which have established the legal relationship enabling them to share taxpayer information with Australia. The update will add the 56 jurisdictions that have entered into information sharing agreements since 2012.

Effective from 1 January 2019

The updated list will be effective from 1 January 2019. This measure supports the operation of the MIT withholding tax system by providing the reduced withholding tax rate only to residents of countries that enter into effective information sharing agreements with Australia.

Take away

Swiss investors investing in Australian MITs should ensure that they will benefit from the reduced tax rates. For certain structure the investment through an MIT might become an attractive alternative given the lower withholding tax rate.

We are happy to review your Australian investment structure to ensure they are as tax efficient as possible.

Contacts

Victor Meyer
+41 58 792 43 40
victor.meyer@ch.pwc.com

Benjamin De Zordi
+41 58 792 43 17
benjamin.de.zordi@ch.pwc.com

Regula Haefelin
+41 58 792 25 24
regula.haefelin@ch.pwc.com

Silvan Amberg, CFA, CAIA
+41 58 792 44 59
silvan.amberg@ch.pwc.com

Double Tax Treaty – Brazil x Switzerland

Brazilian and Swiss governments signed a Double Tax Treaty (DTT) on 3 May 2018 that regulates the income tax treatment between both countries. The DTT includes provisions to facilitate international cross border investments and transactions such as dividends, royalties, interest and capital flows and is aligned with the Base Erosion and Profit Shifting (BEPS) actions, such as treaty abuse provisions, mutual agreement procedure as well as exchange of tax information.

The DTT as a next step will need to be ratified by both jurisdictions in accordance with their respective domestic law. On the Brazilian side, the DTT must be ratified by the National Congress and on the Swiss side, also the parliament will need to ratify the DTT. Only once ratified by both jurisdictions, the treaty can enter into force. At this stage, it cannot be predicted when exactly the DTT will enter into force though.

Switzerland is one of the biggest investors in the Brazilian market and the DTT demonstrates the high interest in the continuous development of the commercial relationship between the countries by providing investors with clear tax rules and the same time increase transparency.

It is important to highlight that Brazil and Switzerland already signed an Automatic Exchange of Information agreement, which entered into force on 1 January 2018, which will allow the countries to share financial information regarding enterprises and individuals even if the DTT is not in force yet. Switzerland already has an attractive double tax treaty network with Latin American jurisdictions and ratifying and putting into force the Swiss Brazilian DTT will enhance Switzerland’s position for Latin American investments.

In addition, in February 2018, the OECD and Brazil also launched a joint project to examine the similarities and gaps between the Brazilian and OECD approaches to valuing cross-border transactions between associated firms for tax purposes. The project will also assess the potential for Brazil to move closer to the OECD’s transfer pricing rules, which are a critical benchmark for OECD member countries and followed by countries around the world. The development of further DTT’s as well as the intention to close the gap with the OECD also demonstrates that Brazil is seeking to align its practice to the global standards and facilitate investments.

Contact Us

Tiago Feracioli
Manager
Tel. +41 58 792 21 75
tiago.feracioli@ch.pwc.com

Matthias Marbach
Director
Tel. +41 58 792 44 76
matthias.marbach@ch.pwc.com

Stefan Schmid
Partner
Tel. +41 58 792 44 82
stefan.schmid@ch.pwc.com

EMEA PE Webcast Series – Episode Four – VAT consequences of a corporate tax permanent establishment

Tuesday, 17 April 2018, 3.00 – 3.45 pm CET

After a short break, we are pleased to inform you that we will resume the PE Webcast Series, with Episode 4 – VAT consequences of a corporate tax permanent establishment.

In this webcast specialists from our international tax and VAT practice will compare the objectives and concepts of a corporate tax permanent establishment with a VAT fixed establishment (FE).

We will walk through practical examples to demonstrate the interaction of these rules, outlining the VAT consequences of creating a corporate tax PE, as well as the corporate tax position if you have a VAT FE.  As part of the discussion we will highlight trends in the application of PE and FE rules by tax authorities, leading in some cases to a blurring of the concepts.

You will have the chance to raise questions directly to our specialists.

Speakers for episode four will include:

  • Monica Cohen-Dumani – Partner, International Tax Services, EMEA ITS Leader – PwC Switzerland
  • Ine Lejeune – Partner Tax Policy, Dispute Resolution & Litigation – Law Square
  • Herman van Kesteren – Partner Indirect Taxes – PwC Netherlands

Registration Link

Complete the required registration fields and select “Submit”.
Once you have registered, you will receive the WebEx access details. The WebEx will be recorded and you will receive a link to the recording via e-mail after the event using the same details. There will be time for questions and answers with your speakers during the WebEx. Questions can also be sent in advance of the
WebEx session to the following email address: grasiele.neves@ch.pwc.com

We do hope that you will join us online!

Best regards,
Monica Cohen-Dumani

Contact

Monica Cohen-Dumani
Partner, EMEA ITS Central Cluster Leader
+41 58 792 97 18
monica.cohen.dumani@ch.pwc.com

Grasiele Teixeira Neves
International tax services
+41 58 792 98 25
grasiele.neves@ch.pwc.com

Update: Repatriation Tax (Notice 2018-26)

On April 2, 2018, the Department of the Treasury and the IRS released their third notice on the Toll Tax also known as the Repatriation Tax (Notice 2018-26)

Some of the key guidance provided in this latest notice which affect US individuals living abroad are:

  • Extension of time to pay the first installment of the Toll Tax for US individuals living abroad until June 15, 2018, the same date as the automatically-extended personal tax return deadline for these individuals.
  • Clarification on the allowable deductions for US individuals subject to the Toll Tax, who wish to make an election to be taxed similar to a US domestic corporation (i.e. §962 election)
  • US partners holding less than 5% in a partnership structure with investments in US domestic corporations may not be subject to the Toll Tax
  • If a foreign corporation filed an election to be treated as a tax-transparent entity (i.e. check-the-box election) after November 2, 2017, the Toll Tax may still be attributed to its US individual shareholders for the 2017 tax year.

From a practical perspective, US individuals (US national, US green card holder, US tax resident) residing abroad who are investors in a structure holding directly and indirectly, 10% ownership in a US domestic corporation should carefully review their toll tax exposure before June 15, 2018.

For more information, a complete copy of the notice can be found in the following link: https://www.irs.gov/pub/irs-drop/n-18-26.pdf

Contact Us

Richard Barjon, CPA
PwC | US Tax Director
+41 58 792 13 53
richard.barjon@ch.pwc.com

European Commission proposes new rules on the taxation of the digital economy

On 21 March 2018, the European Commission proposed new rules to ensure that digital business activities are taxed in a fair and growth-friendly way in the EU.

Background

While digital businesses have evolved rapidly in the recent past, the current tax rules do not fully fit the modern, increasingly digital economy, resulting often in a misalignment between the place where the profits are taxed and the place where value is created. In order to address the tax challenges from the digital economy the EU Commission presented its so-called “Digital Tax Package”, which mainly consists of two draft Directives and one Recommendation to the EU Member States. This package supports the Commission’s key priority of completing the Digital Single Market, which also takes into account the global dimension: the OECD has committed to bring forward a report on the next steps internationally by 2020.

Legislative proposals in a nutshell

Draft Directive on the corporate taxation of a significant digital presence:

  • To reform corporate tax rules so that profits are allocated and taxed where businesses have significant interaction with users through digital channels (assumption of a taxable digital presence or a virtual permanent establishment);
  • This is the EU Commission’s preferred long-term solution.

With respect to non-EU countries, not captured by this Directive, the EU Commission issued a Recommendation to the Member States for adaption of such rule via the double tax treaty (see also below).

Draft Directive on Digital Services Tax (DST):

  • To introduce a DST of 3% on certain revenues from digital activities;
  • The introduction of a DST is considered as an interim solution until the above long term solution is in place.

As a next step, both legislative proposals will be submitted to the European Council for adoption and to the European Parliament for consultation. If adopted by unanimous vote, the expected effective date would be 1 January 2020.

Legislative proposals in detail

Draft Directive on the corporate taxation of a significant digital presence (long-term, comprehensive solution)

A digital platform shall constitute a significant taxable digital presence in an EU Member State if it fulfils one or more of the following criteria:

  • Total annual revenues from digital services to users in that Member State in a taxable year exceed a threshold of EUR 7 million, and/or
  • Users of digital services in that Member State in a taxable year exceed 100’000, and/or
  • Business contracts for digital services in that Member State in a taxable year exceed 3’000.

The new rules would also change how profits are allocated to Member States in a way which better reflects how companies can create value online: for example, depending on where the user is based at the time of consumption or where the value is generated through user participation.

Such directive would apply to all companies that are resident in an EU member state. It would also apply to companies in non-EU member states rendering digital business to EU based users and customers unless there is a double tax treaty in place which does not provide for similar rules on significant digital presence and profits attribution (this is for the time being the case, since currently existing double tax treaties do typically not allow for such digital taxation). Hence the below recommendation to the EU member states to re-negotiate double tax treaties to include such digital business taxation rules.

Draft Directive on Digital Services Tax (short term, interim solution)

Unlike the common EU reform of the underlying tax rules, the interim DST would apply to revenues created from certain digital activities which under the current tax rules would not be taxed in the countries where the value is generated. This DST would only remain in force as an interim measure, until the comprehensive solution is in place. However, it would apply to any company rendering digital services in the EU irrespective whether an EU member state based company or not and irrespective of existing double tax treaties.

The tax would apply to revenues created from activities where users play a major role in value creation and which are the hardest to capture with current tax rules, such as those revenues:

  • created from selling online advertising space;
  • created from digital intermediary activities which allow users to interact with other users and which can facilitate the sale of goods and services between them;
  • created from the sale of data generated from user-provided information.

The DST would only apply to companies with total annual worldwide revenues of EUR 750 million and taxable revenues of EUR 50 million in the EU. This would help to ensure that smaller start-ups and scale-up businesses remain unburdened.

Recommendation relating to the corporate taxation of a significant digital presence

In connection with the long term Draft Directive on the corporate taxation of a significant digital presence, the EU Commission also issued an accompanying Recommendation to the EU Member States for cases where the proposed Directive would not apply, i.e. when Member States have tax treaties in place with non-EU countries (which would also be the case for Switzerland).

In particular the EU Commission recommends to Member States to amend their tax treaties with non-EU countries by a) changing the definition of permanent establishment to take into account significant digital presence and b) including rules for respective profit attribution.

For further details regarding the EU Digital Tax Package please refer to the detailed newsletter of the PwC Network EUDTG.

Implications of proposed rules for Switzerland

Although the above legislative proposals are EU Directives, the directives still impact companies operating out of Switzerland or other non-EU states, if finally adopted.

Draft directive on Digital Services Tax:
The DST would affect Swiss groups performing digital services in the EU as the tax becomes due if the user / customer is in the EU, provided they meet the thresholds mentioned above.

Draft directive on the corporate taxation of a significant digital presence:
These rules shall not apply if an entity is resident for tax purposes in a non-EU jurisdiction (e.g. Switzerland) that has a double tax convention (DTC) in force with the relevant Member State, and if the DTC does not provide for a taxable digital presence (which is currently the case for all Swiss DTCs). Hence, groups operating out of Switzerland are expected to be affected by this potential measure only in the longer term, i.e. when DTCs are renegotiated (as proposed in the EU Commission’s Recommendation) to include the taxable digital presence, subject also to any further OECD developments.

For further details on the progress of the OECD work in this respect as well as for a summarised overview of the different approaches between the OECD and the EU, please find here OECD’s Interim Report 2018 respectively our PwC Tax Policy Bulletin.

Overall, the attractiveness of Switzerland as a location for digital businesses is not negatively impacted compared to the EU as a result of these directive proposals.

Related VAT Aspects

Even if the digital taxation proposals implicate significant changes in the corporate tax landscape, from an indirect tax (VAT) point of view the taxation of turnovers for digitally provided services at the place of the consumer (B2C) is already in force in the EU since 2015. However, the question remains whether the digital presence will also affect the definition of fixed establishments for VAT purposes and such change would have a major impact on how digitally provided services would be taxed in a B2B context.

Current position of Switzerland regarding taxation of digital economy

The State Secretariat for International Finance (SIF) recently has performed an analysis regarding the taxation of the digitalised economy and is generally committed to tax rules that allow for and promote fair competition. However, there have not been any concrete measures yet. In any case Switzerland holds the opinion that measures outside the scope of DTCs are to be avoided and interim measures (e.g. DST) should be limited in scope and time. Read SIF’s position on taxing the digitalised economy here.

Call for action

At this stage it is not clear yet whether respectively how the proposed directives will be adopted by the EU (formal adoption still pending and subject to unanimity among the EU Member States). Further, also the developments on the OECD BEPS project should be taken into consideration and monitored.

Nevertheless, it is recommendable for groups operating out of Switzerland to:

  • identify the digital services rendered in each of the EU Member States;
  • start performing impact assessments of (i) the DST and (ii) a taxable digital presence in the EU Member States, and
  • continue monitoring the EU legislative process and potential unilateral country measures (such as the unilateral measures in Italy, introducing a new tax on digital transactions effective January 1, 2019).

Your contacts

Stefan Schmid
Tel. +41 58 792 44 82
E-Mail: stefan.schmid@ch.pwc.com

Anna-Maria Widrig Giallouraki
Tel. +41 58 792 42 87
E-Mail: anna-maria.widrig.giallouraki@ch.pwc.com

Christa Elsässer
Tel. +41 58 792 42 66
E-Mail: christa.elsaesser@ch.pwc.com

Jeannine Haiböck
Tel. +41 58 792 43 19
E-Mail: jeannine.haiboeck@ch.pwc.com

Geneva International VAT Breakfast: E-invoicing & hot topics in indirect taxes

E-invoicing & hot topics in indirect taxes

So far, 2018 has been a very dense year for indirect tax professionals with various hot topics arising. In Switzerland, for instance, the recent clear rejection of the initiative “No Billag” will lead to changes in the scope of the radio-television fees that will be applicable to businesses as from 1 January 2019.

At the same time, compliance with e-invoicing and e-archiving obligations are being introduced in various jurisdictions such as Italy. During our upcoming event, we will go through the new rules and the compliance obligations across EU and Switzerland in terms of e-invoicing and e-archiving.

We will also follow up on the definition of fixed establishment providing insight on the recent developments particularly in Poland. The International VAT Breakfast will also feature recent hot topics that can impact businesses operating worldwide, such as the EU commission proposal for flexible VAT rates, the measures to strengthen VAT fraud prevention adopted by EU and non-EU countries and the introduction of the reverse charge mechanism for imports of goods in Portugal as from 1 March 2018.

Finally, as always, we will share with you the most significant developments with respect to the EU and Swiss case law.

To register for this event: Click here

Contact us

Patricia More
Tel.+41 58 792 95 07
patricia.more@ch.pwc.com

US Tax Reform – Impact on US individual owners of foreign corporations (entrepreneurs and small business owners) residing outside of the United States

In an effort for the United States to become fiscally competitive on the world stage, the new US Tax Reform included provisions to move towards a territorial tax system by imposing a “toll tax” on undistributed profits on US-owned foreign corporations. Its purpose is particularly meant to stimulate the economy by motivating corporations to repatriate cash generated from previously untaxed profits abroad to invest in the economy and create jobs.

The following comments will provide a high level overview of the adverse and unfortunate effects US individual shareholders of foreign corporations will endure from the new toll tax and GILTI rules in comparison to US corporate shareholders.

Effective for the last taxable year of a foreign corporation that begins before January 1, 2018, the “toll tax” is a one-time tax of 15.5% on aggregate cash balances and 8% on all other undistributed profits earned since 1987 on the balance sheet of a foreign corporation as of December 31, 2017 or November 2, 2017, whichever is higher. Consequently, future dividend distributions to its US parent will be free from US taxes thus achieving the “territorial tax regime”.

Many of us may have read the headlines on how this toll tax, also referred as the Repatriation Tax, affects US corporate shareholders of foreign corporations, (e.g. Goldman Sachs, Apple: news article) However, the toll tax also applies to US individual shareholders of a foreign corporation that is a Controlled Foreign Corporation (a “CFC”).

A foreign corporation is a CFC if US shareholders own more than 50% of the total combined voting power of its stock or more than 50% of the stock’s total value. For this purpose, the law defines a US shareholder as any US person who owns 10% or more of a foreign corporation, including a US citizen, a green card holder or an individual who meets the physical presence test (or elects) to be considered as a tax resident of the United States. These rules also apply if a US person resides outside the United States due to the preservation of the worldwide tax regime for US individuals.

The method to arrive at the toll tax liability is relatively complex. The 15.5% and 8% effective rates are in fact prescribed as “equivalent percentages”. A deduction based on the US corporate tax rates is used to arrive at these effective rates. To the extent the toll tax is due for a CFC as of December 31, 2017, the deduction is based on the 2017 corporate tax rate of 35% (max) rather than the individual rate of 39.6% (max) and US individuals will have to follow that same corporate rate deduction mechanism using the 35%, not the individual rate. Hence, US individual shareholders of a CFC will bare a higher toll tax burden than that of a US corporate shareholder. While this provision provides for partial foreign tax credits to decrease the net toll tax due of US corporate shareholders, individuals are not allowed to claim foreign tax credits to reduce their net toll tax liabilities. In addition, US individuals will continue to pay US taxes on future dividend income, not previously taxed, received from their CFCs as the new dividend exemption only applies for US corporate shareholders.

An election to pay the toll tax liability in installments over an 8-year period is available and if such election is made, the first payment is due by the original due date of the shareholder’s 2017 US tax return determined without regard to any extension i.e. April 15, 2018 for a calendar year taxpayer. To date, it is unclear if individual US shareholders residing abroad will be allowed the regular automatic extension until June 15, 2018 to make their first toll tax payment.

Also included in the US Tax Reform are the GILTI implications. Going forward, applicable for the first tax year of a CFC beginning after December 31, 2017, the US will also require individual shareholders of the CFC to include in their annual taxable income a “global intangible low-taxed income” or GILTI; which notwithstanding its name, is not limited to intangibles nor low-taxed income. Prior to the GILTI rules, CFCs with active business income used to qualify for deferral from US taxes and received qualified dividend treatment (preferential tax rates if from a treaty country) at the time profits were distributed to their US shareholders.

The GILTI rules practically eliminate the active business income deferral. The treatment for US corporate shareholders is again different from that of a US individual. While a 50% deduction will be allowed to reduce the annual taxable GILTI including an available 80% deemed foreign tax credit against the GILTI tax for US corporate shareholders, US individuals subject to the GILTI tax will not benefit from such deduction nor the foreign tax credit. Accordingly, it is strongly recommended that the current organizational structure, involving a CFC with a 10% or more US individual shareholder (resident in or outside the United States), is carefully reviewed under the new rules all the while exploring certain available elections permitted by the IRS.

Every circumstance is different and the new rules are extremely complicated. Although US tax practitioners are still waiting for more guidance from the IRS and how it will particularly impact their clients, it is uncertain if the impact on individuals will be addressed further. It is crucial for US individual shareholders of foreign corporations to work closely with their advisors to consider potential planning opportunities on how they can reduce, or prepare for, these additional tax burdens.

If you have any questions or wish to discuss, our US tax experts at PwC in Switzerland are available to assist.

Contact Us

Richard Barjon, CPA
PwC | US Tax Director
+41 58 792 13 53
richard.barjon@ch.pwc.com

US Tax Reform from a Swiss US investors perspective

Wednesday, March 14, 9:30 am -1:30 pm, PwC Bern

PwC is pleased to host a seminar with the Embassy of the United States and K&L Gates followed by a luncheon, on the U.S. Tax Cuts and Jobs Act signed by President Trump in December 2017. Tax professionals from PwC Switzerland and K&L Gates of South Carolina will highlight the implications of the U.S. federal tax code changes for current and future Swiss and Liechtenstein investors and U.S. companies operating in Switzerland.

When: 

Wednesday, March 14, 9:30 am -1:30 pm, PwC Bern,  Bahnhofplatz 10, 3001 Bern.

What:

  • “US Tax Reform in a Nutshell & How US Tax Reform impacts doing business and investments between the US and Switzerland”
  • “It’s a competition: Understanding the State and Local Incentive Process”
  • “Impact on European inbound US investment – One State’s Perspective”

The detailed agenda of the event will be provided upon registration.

Attire: 

Business

Registration:

Kindly respond by March 5 to Mr. Sandor Galambos, galamboss@state.gov or 031 357 7237 or Nathalie Fretz, nathalie.fretz@ch.pwc.com

Contact Us

Martina Walt
PwC | Partner – International Tax Services
Office: +41 58 792 68 84 | Mobile: +41 79 286 60 52
Email: martina.walt@ch.pwc.com
PricewaterhouseCoopers Ltd
Birchstrasse 160, 8050 Zurich
http://www.pwc.ch

EMEA Webcast: EMEA ITS US Tax Reform Series – Practical Guidance for European Multinationals – Episode 4: State tax implications of federal tax reform

State tax implications of federal tax reform

Wednesday, 7 February 2018, 4.00 – 5.00 pm CET

While US tax reform is focused on measures at federal level, it will lead to a diverse and wide-ranging number of state tax implications as a result of how/whether states conform to the federal Internal Revenue Code provisions. There are accordingly a number of critical elements that have the potential to significantly affect state tax and financial statements, such as deemed repatriation toll charge; interest expense limitations; and the international provisions discussed on our previous calls, namely BEAT, GILTI and FDII.

Episode 4 of our webcast series will therefore look in more detail at the state tax implications, with particular focus on the international measures and the tax accounting implications.

We will be joined by our state tax and tax accounting specialists in order to provide an overview of the key areas you should be considering.

Please follow the link below to register for episode 4 and note that recordings will be available if you register and you cannot join the live session itself.

To register for Episode 4: Click Here

In case you were not able to join our previous episodes and would like to view the recording, find hereafter the required links (you will need to register to watch the recording):

Contact Us

Richard Brunt
Tel.+41 58 792 81 82
richard.brunt@ch.pwc.com

Grasiele Teixeira Neves
Tel.+41 58 792 98 25
grasiele.neves@ch.pwc.com