The structure of a trading group

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The legal structure of a commodity trading group headquartered in Zug often follows a pattern along the following lines. At the top stands a holding company, which may be incorporated in Switzerland or abroad, as in the case of Glencore plc in Jersey. Below it, a principal trading company in Zug carries on the trading business: it concludes the purchase and sale contracts, bears the price and credit risks, holds the hedging positions and receives the trading profits. Offices in other trading centres, such as London, Singapore, Dubai, Houston or Geneva, are organised as branches or subsidiaries of the principal company and perform marketing, origination and operations functions for which they receive a remuneration determined by transfer pricing. Production assets, such as mines, refineries, terminals and ships, are held by separate subsidiaries in the countries where they are located. Financing is raised at the level of the holding company, the principal company or specialised finance subsidiaries.

The principal company in Zug is the heart of this structure. Its tax treatment, once governed by the status regime for mixed companies, is now determined by the ordinary cantonal rate and the global minimum tax. Its substance, the presence in Zug of the traders and managers who take the decisions and control the risks, determines whether the profits allocated to it will be respected by the tax authorities of the other countries. Its governance determines whether it can meet the compliance obligations that the regulators and prosecutors of several states impose on it. The practitioner who structures or reviews a trading group must therefore begin with the principal company in Zug and ask whether its functions, its staff and its controls correspond to the profits and the risks that the group attributes to it.

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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The structure of a trading group

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