Atty. Michel Abt

Michel Abt is the co-head of the Tax Group and a member of the Banking & Finance Group.

He advises both natural persons and legal entities such as banks, family offices and trusts, as well as investors and administrators whether in Switzerland or abroad, with a specific emphasis on asset holding structures.

Since 2009, Michel Abt has been advising a large number of French clients in their regularization process and has assisted them with their tax optimisation. He thus addresses all tax matters arising therefrom such as gift and inheritance issues in a cross-border perspective. He also assists clients in their voluntary disclosure to Swiss authorities as well as to foreign authorities enducting the same disclosure programmes, particularly in Italy.

Michel Abt has significant expertise in negotiating tax rulings with various Swiss tax authorities (Geneva, Vaud, Valais, Lucerne, Schwyz, etc.) for the account of foreign high net worth clients wishing to settle in Switzerland. He assists them in their asset restructuring before their relocation and within their estate and succession planning.

Furthermore, Michel Abt advises inheritors in the context of their international, multi-jurisdictional and complex successions both in a legal and fiscal perspective. He also advises on artistic heritages, their mode of ownership, their transmission and their sale.

Finally, Michel Abt is an expert in financial market regulation, particularly in investment funds.

Areas of expertise

- Tax law, in particular :

• Natural persons taxation (including tax engineering and wealth management, transmission and protection of assets, delocalisation et tax status)
• Companies and managerial taxation
• Property taxation (including structuration of real estate investments, and their financing)
• Collective investment schemes taxation
• Tax procedures (including unsolicited announcements and tax amnesties)

- Banking and financial regulations, in particular in relation to collective investments schemes (securities and real estate funds)