Compliance in wealth planning

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The end of banking secrecy changed wealth planning as profoundly as it changed private banking. Structures that once served to conceal assets from tax authorities are now reported under the automatic exchange of information. The Common Reporting Standard requires financial institutions to look through trusts, foundations and companies to identify their controlling persons and beneficiaries, and to report them to the authorities of their countries of residence. The European Union's directive on mandatory disclosure of cross-border arrangements, known as DAC6, requires intermediaries in the European Union to report certain arrangements that bear hallmarks of aggressive tax planning.¹ Switzerland has not adopted DAC6, yet Swiss advisers who work with intermediaries in the European Union must take it into account.

The modern wealth planner therefore works on the assumption that every structure will be visible to the tax authorities of every relevant country. What matters today is whether a structure is lawful, appropriate and properly declared in every country concerned, because concealment has ceased to be an option. This shift has made wealth planning more demanding and more honest. It has also increased the value of advice, because the cost of a mistake is now borne openly by the family in the form of taxes, penalties and, in some cases, criminal proceedings.

Notes

On the treatment of trusts and foundations under the CRS (controlling persons, reporting of settlors, trustees, protectors and beneficiaries) and Council Directive (EU) 2018/822 (DAC6) on mandatory automatic exchange of information in relation to reportable cross-border arrangements, see the OECD and EU publications. To be verified. ↩

For general information only. This article does not constitute legal or tax advice, does not replace advice on an individual case and creates no lawyer-client relationship. It reflects the legal position as of August 2025.

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Dr Alexander Ressos, TEP

Rechtsanwalt/Attorney-at-Law

I am a Swiss attorney-at-law and also admitted as a solicitor in Hong Kong and in England & Wales, with almost 25 years of experience.

Together with my multilingual team, including Chinese, Japanese, Korean, Russian, Ukrainian and French native speakers, I advise companies and their owners from around the world on the full range of banking, corporate, commercial and tax law matters in Switzerland, including international tax planning, fiduciary services, and legal family office services including immigration & relocation or real estate investments. My practice has a particular focus on clients from growth and frontier markets in Greater China, Central Asia and the Caucasus, the rest of Asia, the Middle East, Africa and Latin America, and I equally advise clients from Europe and North America. Through an affiliated Swiss trust company, we also take care of the incorporation and ongoing administration of their companies and other structures, including accounting, tax returns and corporate secretarial services, and I serve as a professional director where required. With the support of a network of first-class cooperation partners, I also implement solutions worldwide.

My approach is to act as a trusted advisor who works directly with decision-makers, on an equal footing: I start from what you want to achieve and shape every structure, contract and tax decision around your commercial goals and how it improves your after-tax return. As “lawyers who make it happen”, my team and I stay involved until your company is set up, your structure is in place and your transaction has closed, and we remain available for any follow-on work that may be required. You benefit from bespoke solutions and personal attention, and sound, friendly and practical advice. We are not the lowest-cost provider in the market, nor do we intend to be; our aim is to deliver well-founded, proper solutions and excellent value for money.

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Compliance in wealth planning

Notes

Setting up or expanding in Switzerland?