Tax and Transparency

From secrecy to transparency

Within a decade Switzerland moved from banking secrecy to automatic exchange of information with more than one hundred states, a register of beneficial owners and the global minimum tax. Companies and families who hold assets through Switzerland must now structure and report correctly from the outset.

For foreign readers the change has practical consequences. Swiss banks now report account information to the tax authorities of the holder's country of residence, and a structure that cannot be explained to those authorities will soon be questioned by the bank itself. Planning therefore begins with the question of where each person and company is resident for tax purposes and what will be reported where.

Planning within the rules

Switzerland remains attractive for well-organised companies. Profit tax is levied by the Confederation, the cantons and the communes, and the combined burden differs considerably from canton to canton. Since 2024 large international groups within the scope of the global minimum tax are subject to a Swiss top-up tax, which ensures that the effective rate reaches the agreed minimum of 15 per cent.

Swiss tax authorities are known for their willingness to discuss a planned structure in advance and to confirm its treatment in a tax ruling. Such rulings are now exchanged spontaneously with other states where the rules on transparency require it. A structure that is sound on its merits gains legal certainty from this dialogue, while an artificial one gains little.

In this section

The articles explain the automatic exchange of information in practice, the transparency register and the revised Anti-Money Laundering Act, the taxation of companies and holding structures, and the treaties with China, Hong Kong and African states.