Dr. Marcel R. Jung, LL.M.

Partner/Certified Tax Expert, Zurich

Schiffbaustrasse 2 | P.O. Box | CH-8031 Zurich | Switzerland

Schiffbaustrasse 2 | P.O. Box | CH-8031 Zurich | Switzerland

marcel.jung@mll-legal.com

Profile

Marcel Jung is attorney at law and certified tax expert. He is co-head of MLL’s tax practice group. He has extensive experience in Swiss and international tax law. He is also a highly experienced tax litigator in both Swiss and international tax cases in the Swiss courts up to the Supreme Court.

His professional interest focuses on the tax challenges of the digital economy, global tax transparency and cross-border exchange of information, BEPS Action Plan of the OECD and its impact on business and group taxation and private investment structures, multilateral agreements in tax matters, tax arbitration and protection of taxpayers’ rights.

Practice Areas

Industry Groups

Blockchain Technologies

Rankings & Awards

«Marcel Jung is an outstanding tax lawyer with specific expertise on international tax matters.» – Legal 500 EMEA, Tax, 2020
«Marcel Jung earns plaudits from peers as «an outstanding professional with a top-tier reputation in corporate tax matters.» – Who’s Who Legal Switzerland, Corporate Tax 2022

Deals & Cases

Provided pre-immigration tax planning advice to U.S. resident individuals in conjunction with a U.S. law firm and a U.S. family office on their move from the U.S. to Switzerland. Pre-immigration tax planning advice included restructuring of worldwide assets and U.S. investments and U.S. trusts under U.S. income tax and U.S. estate tax treaties to achieve a tax-efficient investment structure
Advised a Swiss tax resident individual client and U.S. green card holder under U.S. income tax and U.S. estate tax treaties to remain within the corridor between U.S. immigration law and the tie-breaker rule in the Swiss-U.S. income tax treaty
Represented several members of a Spanish family in a Spanish request for information on multiple information proceedings before the Supreme Court. The matter is related to EC Treaty infringement proceedings against Spain over Modelo 720 and Paradise Papers
Successfully represented a Swiss defendant in criminal tax proceedings in a case where the defendant imported a Swiss watch without a Swiss VAT declaration at the Swiss customs office. The information were spontaneously exchanged under the Protocol on Mutual Administrative Assistance in Customs Matters of June 9, 1997, between the European Community and Switzerland, which was added to the Agreement of July 22, 1972, between the European Economic Community and Switzerland
Successfully represented a German defendant in criminal tax proceedings in a case where the defendant left Germany, moved his tax residence to Switzerland, liquidated a Swiss company and moved back to Germany. The Federal Tax Administration, Criminal Matters and Audits Division, issued an order withdrawing the criminal tax prosecution due to the statute of limitations
Successfully represented a taxpayer in an income tax case against the Federal Tax Administration where two investors transferred a jointly held property to privately held real estate companies within 10 months of the acquisition and the companies sold the property to a high net worth individual 10 days after the transfer with a profit margin of 82.5%. The Supreme Court decided in favor of the taxpayer based on rules of evidence and upholds an interrogator’s award