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Michael Tobler
Zurich
Partner - Tax

Michael Tobler

+41 43 960 71 50
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Michael Tobler is Partner of the Service Line Corporate International Tax in Switzerland. He is Head of M&A Tax.

Professional experience

Michael Tobler focuses on international corporate tax advisory of Swiss based/multinational companies and has a special interest in M&A and cross-border structuring.

He is experienced in serving international groups in their tax compliance and planning needs. Michael Tobler has successfully advised on numerous acquisitions and joint ventures for private equity investors as well as multinational enterprises of various industries.

He has more than 17 years of professional tax consulting experience. Prior to joining Grant Thornton Switzerland by the end of 2013, he worked for a Big 4 company in Zurich. Originally, Michael Tobler started his career in an American chemical company working in the risk management of the treasury department.

Professional qualifications and memberships

Michael Tobler has a degree in Business Administration with a major in Banking and Finance and is a Swiss certified tax expert.

He is a member of EXPERTsuisse, the Swiss Turnaround Association and of the Swiss-Indian Chamber of Commerce.

Languages

Michael Tobler’s mother tongue is German. 
He is fluent in English.

 

Download CV PDF [ 131 kb ]

Qualifications
  • Swiss certified tax expert
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Swiss withholding tax: Due date of hidden profit distributions
Tax Swiss withholding tax: Due date of hidden profit distributions
Practice and doctrine assume different points in time for the due date of hidden profit distributions. The Swiss federal supreme court recently approved the Swiss federal tax authorities’ complaint in matters of public law against the judgment of the Federal Administrative Court and confirmed that the due date of hidden profit distributions should be the booking date. For simplicity and practical reasons, the end of the financial year is considered as the due date for several hidden profit distributions. Late interest of currently 4.75% becomes due 30 days after due date of hidden dividend distributions. To cover withholding tax liabilities and late interest thorough tax indemnification is crucial in M&A transactions.
Michael Tobler
Michael Tobler
| 4 min read | 16 Oct 2024
M&A transactions: Hidden profit distribution. A simulated loan issue at the level of a Swiss target company could trigger adverse Swiss tax consequences for the buyer.
Tax M&A transactions: Hidden profit distribution. A simulated loan issue at the level of a Swiss target company could trigger adverse Swiss tax consequences for the buyer.
A taxpayer had a debt to a Swiss limited liability company/GmbH held by him, for which the cantonal tax authorities had refrained from claiming a personal taxable income under certain conditions communicated in writing and accepted by the taxpayer. The taxpayer/borrower subsequently breached these conditions with the result that the cantonal tax authorities qualified the loan receivable as a simulated loan.
Michael Tobler
Michael Tobler
| 3 min read | 26 Aug 2024
M&A transactions: Indirect partial liquidation theory could trigger tax indemnification of seller by the buyer.
Tax M&A transactions: Indirect partial liquidation theory could trigger tax indemnification of seller by the buyer.
An indirect partial liquidation clause is standard in share purchase agreements. However, buyers are well-advised to carefully plan the acquisition of a Swiss target company as well as the subsequent integration and prepare together with sellers a defensive argumentation to disprove application of the indirect partial liquidation theory.
Michael Tobler
Michael Tobler
| 3 min read | 09 Jul 2024
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Michael Tobler
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Michael Tobler
Partner - Tax
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