Many international groups hold their subsidiaries, intellectual property or financing through a Swiss company. The articles collected here explain how Swiss holding companies are taxed, which legal form and canton suit a holding, licence or finance company, how dividends and interest leave Switzerland, and what the global minimum tax changes for large groups. They also cover transfer pricing, the substance a Swiss company needs in practice, the migration of a company's seat into Switzerland, the resident director required by law, and why structures that rely on a Swiss address alone no longer work.
A Swiss holding company is often the centre of an international group: it holds the subsidiaries, receives their dividends and finances them. Where the holding sits, how it is capitalised and how much substance it has decide how much of the group's profit reaches its shareholders.
Since the abolition of the former cantonal holding privileges in 2020, a Swiss holding company is taxed at the ordinary rates of its canton. Dividends and capital gains from qualifying participations nevertheless remain largely exempt through the participation deduction, which applies to holdings of at least 10 per cent or with a market value of at least one million francs.
Tax treaties, banks and foreign tax authorities increasingly ask whether a holding company is actually managed in Switzerland. Real decision-making, qualified board members and proper documentation of board meetings are therefore of practical importance. A company limited by shares must have at least one person resident in Switzerland who can represent it, and a limited liability company must meet a comparable requirement.
The choice of legal form also affects capitalisation. A company limited by shares requires a share capital of at least 100,000 francs, a limited liability company at least 20,000 francs. Capital contributed by shareholders beyond the nominal capital can generally be repaid later without withholding tax, which makes the way a group finances its Swiss holding a question worth settling at the start.
The articles explain the taxation of Swiss holding companies, the choice between an AG and a GmbH, the Swiss vehicles used in African projects, why domiciliary companies with a Swiss address alone have had their day, and the role of a professional resident director.
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