Practitioner's note: reviewing a family's structures after a move to Zug

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The practitioner who advises a family that has moved to Zug, or that plans to do so, should review its structures in light of the following questions. How are the family's trusts and foundations treated for Swiss income, wealth, inheritance and gift tax purposes, and does the settlor or founder retain powers that make them transparent? Does the Swiss recognition of the trusts under the Hague Convention protect the trust assets as intended? Are there mandatory rules of Swiss law, such as forced heirship and matrimonial property, that could affect them? Which law governs the succession of each family member, and should a choice of law be made or revised? What is the matrimonial property regime of the spouses after the move, and should a marriage contract be concluded? Are the family's companies and holding structures adapted to Swiss tax law, including the partial taxation of dividends and the rules on indirect partial liquidation? Is there a plan for the succession of the family business, taking advantage of the increased freedom of disposition under the revised succession law? And are the family's charitable activities organised in a way that allows them to benefit from the Swiss tax exemptions?

For general information only. This article does not constitute legal or tax advice, does not replace advice on an individual case and creates no lawyer-client relationship. It reflects the legal position as of September 2025.

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Dr Alexander Ressos, TEP

Rechtsanwalt/Attorney-at-Law

I am a Swiss attorney-at-law and also admitted as a solicitor in Hong Kong and in England & Wales, with almost 25 years of experience.

Together with my multilingual team, including Chinese, Japanese, Korean, Russian, Ukrainian and French native speakers, I advise companies and their owners from around the world on the full range of banking, corporate, commercial and tax law matters in Switzerland, including international tax planning, fiduciary services, and legal family office services including immigration & relocation or real estate investments. My practice has a particular focus on clients from growth and frontier markets in Greater China, Central Asia and the Caucasus, the rest of Asia, the Middle East, Africa and Latin America, and I equally advise clients from Europe and North America. Through an affiliated Swiss trust company, we also take care of the incorporation and ongoing administration of their companies and other structures, including accounting, tax returns and corporate secretarial services, and I serve as a professional director where required. With the support of a network of first-class cooperation partners, I also implement solutions worldwide.

My approach is to act as a trusted advisor who works directly with decision-makers, on an equal footing: I start from what you want to achieve and shape every structure, contract and tax decision around your commercial goals and how it improves your after-tax return. As “lawyers who make it happen”, my team and I stay involved until your company is set up, your structure is in place and your transaction has closed, and we remain available for any follow-on work that may be required. You benefit from bespoke solutions and personal attention, and sound, friendly and practical advice. We are not the lowest-cost provider in the market, nor do we intend to be; our aim is to deliver well-founded, proper solutions and excellent value for money.

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