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CASE STUDY – INBOUND ACTIVITY

NEXIA

FRIEDMAN Comptables agréés – Chartered Accountants

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NEXIA

FRIEDMAN

GWhiz Consultants Inc.

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Case Study - Inbound Activity

NEXIA

FRIEDMAN

GWhiz Consultants Inc. (“GWhiz”) provides computer programming and consulting services

GWhiz is based in Switzerland and has, until now, concentrated mainly on Swiss clients

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Case Study - Inbound Activity

NEXIA

FRIEDMAN

GWhiz believes that its services would add value to clients around the world  As a result, the CFO of GWhiz has approached you to inquire about the tax implications of providing services in your country, and provides you with following facts:

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Case Study - Inbound Activity

NEXIA

FRIEDMAN

• GWhiz does not have any physical location in your country.

•  GWhiz has recently signed an engagement letter with a large payroll processing corporation in your country to provide computer programming and consulting services.

 

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Case Study - Inbound Activity

NEXIA

FRIEDMAN

•  In order to provide these services, GWhiz’s employees will perform some of the work in its offices in Switzerland, but will have to send between five and fifteen employees to work on the client’s premises in your country.

• The duration of the contract will be between six and twelve months.

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Case Study - Inbound Activity

NEXIA

FRIEDMAN

GWhiz is very optimistic about its opportunities for growth in your country and expects to enter into additional similar contracts in your country in the near future.  

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Case Study - Inbound Activity

NEXIA

FRIEDMAN

  

The CFO of GWhiz has asked you the following questions:

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Case Study - Inbound Activity

NEXIA

FRIEDMAN

1.  What level of activity of a foreign company triggers income taxation in your country? Is it necessary to have a permanent establishment in your country in order to be subject to income taxation there?

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Case Study - Inbound Activity

NEXIA

FRIEDMAN

2.  What are the income tax implications in your country for GWhiz employees performing services for a company from your country, but who are physically performing those services in Switzerland?

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Case Study - Inbound Activity

NEXIA

FRIEDMAN

3. What are the income tax implications in your country for GWhiz employees performing services for a company from your country if those services are being physically performed in your country?

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Case Study - Inbound Activity

NEXIA

FRIEDMAN

4. When is a foreign company obligated to register/report and pay payroll taxes in your country?

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Case Study - Inbound Activity

NEXIA

FRIEDMAN

5. When does a foreign company have to register for and charge VAT in your country?

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Case Study - Inbound Activity

NEXIA

FRIEDMAN

6. If GWhiz decides to have a physical presence in your country which creates a permanent establishment there, what are the differences in income taxation if it were to be operated as a branch of GWhiz versus a subsidiary of GWhiz incorporated in your country?