Switzerland is located in the heart of Europe and, whilst not a member of the EU, enjoys many bilateral treaties with the EU as well as an extensive range of International Double Tax Treaties.

Very efficient asset protection tool. Exemption or reduction of income tax on Dividends from “qualifying participation's”, exemption or reduction of corporation taxes on Capital gains arising on the sale of “qualifying participation's”. Deductibility of accrued and paid external and intra-group borrowing costs.

Exemption from Witholding Taxes under certain double tax treaties and of EU shareholders holding in excess of 25% the share capital if held for at least 2 years. Low income taxes on ancillary activities. Foreigners may own 100% of all the shares.

A careful design of corporate structure using a Swiss company can achieve substantial tax savings. Swiss GmbH is exempt from all taxation if structured as Holding company. If regular business activities are conducted the Federal taxes apply with 7,83%.

Confidentiality

• Beneficial owners' details – Not part of public record
• Shareholders' details – are part of the public record, if you wish to avoid it then please request a nominee service
• Directors' details – are part of the public record, if you wish to avoid it then please request a nominee service

Taxation

Switzerland is divided into 26 cantons, and each canton has its’ own tax system. In general, in Switzerland there is a three-level tax system:

• At a federal level - the federal profit tax (3.63% - 9.8%) and taxes to export of the capital (35%);
• On canton level - the basic profit tax (20% - 35%);
• Communes assess incomes, basically in percentage terms fr om canton taxes. Depending on a kind of carried out activity, such as the company (holding, administrative and another) and canton wh ere the company is registered, are applied various rates of taxes to incomes.

The Swiss tax system grants holding companies privileged tax status at the cantonal level, when the following three conditions are met:

• The company articles must state that the main activity of the company is the long-term management of equity investments.
• The company must not have any operating business activity in Switzerland. Certain activities are accepted, such as managing the company and its investments, providing services on behalf of the consolidated group, debt financing of subsidiaries, and/or the holding and exploitation of Intellectual Property.
• In the long term, either the company’s participators must represent 2/3 of the assets in its balance sheet or the income derived from such participators (dividends/capital gains) must represent at least 2/3 of its total income. The shares of corporations, limited-liability companies and cooperatives, as well as certificates of participation are considered as participators.

Providing these conditions are met, the Swiss Holding Company would be exempt from cantonal tax in Zug (other cantons vary) and also would only pay a reduced rate of Capital tax at 2 per mille.

At the Federal level, income is subject to an effective tax rate of 7.83%. However, dividend income derived from and capital gains made on the disposal of qualifying participations are subject to a participation deduction, which generally results in a complete tax exemption.

The Canton of Zug has, with the revised tax law, further improved what were already attractive conditions for legal entities and has strengthened its position as the canton with one of the lowest tax costs. Companies active in the canton of Zug will continue to enjoy the attractive location benefits.

One decisive advantage of Zug as a business location is, that not only does it have low rates of taxation but uncomplicated, unbureaucratic communication between the cantonal tax authorities and the tax-payers.

• Private Limited Liability Company
• Stock Corporation
• Sole Proprietorship