Why Zug

Several factors made Zug a plausible seat for the pipeline company. The shareholders came from four countries, which made a neutral seat attractive for their joint venture. While Switzerland offered political neutrality and a legal system that all shareholders trusted, Zug offered low taxes and a professional environment accustomed to international joint ventures. Gazprom already had business connections in Switzerland through its trading activities. The canton was known for the speed and pragmatism of its commercial register and its tax administration.

The tax advantages were significant for a pipeline company, which earns its income from the transport fees paid by the shippers of gas. Under the cantonal tax regime before 2020, a company whose business activity took place abroad could benefit from a reduced rate of profit tax. Nord Stream's pipeline lay entirely outside Switzerland, in the Baltic Sea, while the company's management and administration were in Zug. That combination fitted the model of the mixed or domiciliary company that Part B described, although the company's precise tax position has never been published.

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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