Tag: Intangible asset
An asset that is not physical (and not monetary) in nature.
Switzerland vs A AG, September 2021, Administrative Court, Case No SB.2020.00011/12 and SB.2020.00014/15
/ Acquisition of shares, Administrative Court, Arm's length principle, Business restructuring, Business Restructuring, CUP method, Decision in favor of tax authority, Discretionary assessment, Hidden distribution of profits, Intangible asset, Intangibles - Goodwill Know-how Patents, Purchase Price Allocation (PPA), Switzerland, Transfer of intangibles, Valuation - DCF and CUT/CUPs
A AG, which was founded in 2000 by researchers from the University of Applied Sciences D, has as its object the development and distribution of …, in particular in the areas of ….. It had its registered office in Zurich until the transfer of its registered office to Zug in 2021. By contract dated 16 June 2011, it was taken over by Group E, Country Q, or by an acquisition company founded by it for this purpose, for a share purchase price of EUR …. On the same day, it concluded two contracts with E-Schweiz AG, which was in the process of being founded (entered in the Commercial Register on 7 September 2011), in which it undertook to provide general and administrative services on the one hand and research and development on the other. As of 30 September 2011, A AG sold all ”Intellectual Property Rights” (IPR) and ”Non-Viral Contracts” to E-Company, a company in U with tax domicile on ... Read more