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Consultancy fees to Switzerland

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Hi all

I have a client that owns a corporate financing company. She also sits on the board of a company in Switzerland. 

She needs to invoice the Swiss company for her services c£350k. All of the services are performed in Switzerland.

1. What is the VAT treatment? I thought exempt due to it being consultancy on intellectual services performed where the customer belongs?

2. She wants to know whether to invoice from the company or individually. If doing it from the company, she wants to drawdown pretty much the full amount so I am thinking to avoid a major double tax charge it may be better to invoice individually. If the supply is VAT exempt then no issues in terms of VAT registering her. 

I am doubting myself but it seems the best option. Would appreciate thoughts?

Many thanks


Replies (3)

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Lone Wolf
By Lone_Wolf
17th Sep 2018 15:43

Surely the answer to your second point comes down to who was engaged to do the work, i.e. did she as an individual engage with the Swiss company, or did her Ltd company engage with the Swiss company to carry out the work, supplying her to carry it out.

Making a decision as to who should invoice the work after the fact, based on what gets the best tax position, sounds like tax evasion to me...

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Replying to Lone_Wolf:
By Tax Conundrum
17th Sep 2018 16:09

She hasn't actually carried out the service yet, so no, not tax evasion at all but simply asking how best to structure her affairs.

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By accountantccole
18th Sep 2018 11:44

Any Swiss rules to consider? If she is performing duties there, particularly earning that sort of figure, even if invoiced via a UK co are you sure there isn't a Swiss payroll needed or Swiss trade of the UK co?
Is the client going to want to pay her personally and risk an employment relationship?

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