Swiss companies do not benefit from the EU Parent-Subsidiary Directive or EU-wide VAT harmonisation.
EU CFC rules may apply if Swiss structures generate passive income and do not have sufficient substance.
Swiss banks require strict KYC checks, evidence of the origin of assets and proof of genuine business activity.
Swiss companies are subject to automatic exchange of information under CRS (Common Reporting Standard) as well as transparency obligations regarding beneficial owners.
Switzerland is a highly developed non-EU country in Central Europe (bordering Germany, France, Italy, Austria and Liechtenstein) with around 9 million inhabitants and the Swiss franc (CHF) as its currency. It is still regarded as a premium location for entrepreneurs and high-net-worth individuals seeking a stable, efficient and tax-optimised environment. With its long tradition of financial confidentiality, a strong banking sector and cantonal tax competition, Switzerland is particularly attractive for structuring private wealth and relocating family offices.
Switzerland offers an expenditure-based taxation model (lump-sum taxation) for foreign nationals who move their tax residence to Switzerland and do not engage in gainful employment there. Tax is calculated on the basis of a negotiated minimum assessment base derived from living expenses rather than worldwide income, subject to minimum thresholds under federal and cantonal law.
EU clients, especially from Germany, must however take expanded tax obligations into account. Under the German–Swiss double taxation agreement, Germany may, under certain conditions, continue to tax former taxpayers for up to five years after departure. Careful planning is therefore essential.
Under Swiss law, at least one person resident in Switzerland must be able to represent the company with legal effect (sole or joint signatory authority). In practice, this is often implemented as a requirement for a Switzerland-resident director or authorised signatory.
Switzerland has numerous banks, but opening an account is by no means straightforward. Enhanced due diligence should be expected, particularly for foreign owners, holding structures, crypto-related business models or low-substance arrangements.
From the EU’s perspective, Switzerland is not officially considered a tax haven. It was removed from the EU monitoring list (“Grey List”) in 2019 after changes to its tax legislation. Today, Switzerland cooperates closely with EU states, Swiss banks report financial information in line with international standards, and anonymous offshore accounts are effectively no longer possible.
Nevertheless, some EU countries scrutinise a move to Switzerland with particular tax attention.
Germany applies particularly strict rules in this respect. Under certain conditions, German tax authorities may continue to tax German income and assets for up to five years after departure.
France and Austria also have exit-tax or subsequent-taxation rules, although these differ in scope and duration.
Other countries such as Spain, Italy or the Netherlands do not have comparable extended subsequent-taxation rules. However, exit taxation may arise when relocating, particularly on shareholdings and capital investments, and CFC rules may apply if foreign companies are maintained without sufficient substance.
Switzerland is not suitable for clients who expect unrestricted EU market access or anonymity in the ownership structure. Swiss structures require transparency, economic substance and compliance, but in return they offer long-term legal stability and tax planning certainty.
Contact us to check whether Switzerland is the right jurisdiction for your private and business structure.
Under Swiss law, at least one person resident in Switzerland must be able to represent the company with legal effect (sole or joint signatory authority).
Corporate tax is, depending on the canton, roughly between 12–20 %
Dividends are subject to a 35 % withholding tax
A VAT number can generally be issued within around 2–4 weeks after proper incorporation and registration.
Yes, in many cases the incorporation process can be handled remotely.
| Tax Burden | Banking | Reputation | Bureaucracy | Legal Security | Costs | |
|---|---|---|---|---|---|---|
| USA | 21-0% |
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from EUR 1,900 |
| Singapore | 0% |
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from EUR 2,950 |
| Hong Kong | 0% |
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from EUR 1,900 |
| Cyprus | 15% |
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from EUR 1,900 |
| Malta | 5% |
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from EUR 2,500 |
| Ireland | 12,5% |
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from EUR 1,950 |
| Trust | 0% |
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from EUR 4,900 |
| England | 25-19% |
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from EUR 1,000 |
Your country of residence may impose tax and reporting obligations for foreign business activities and dividend income, in some cases even if profits are not distributed.
Depending on your personal situation, an appropriate holding structure may be required to comply with tax regulations and avoid unnecessary tax risks.
To determine which jurisdiction and structure best meet your requirements, please use the contact form and describe your plans in as much detail as possible.
Our advisers will be happy to review your case and advise you accordingly.
