| Common structures used in Switzerland include: |
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Main purposes:
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Main benefits:
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Swiss Holding Company
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To hold group subsidiaries
To hold significant shareholdings in external companies
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Exemption or reduction of income tax on Dividends from “qualifying participations”
Exemption or reduction of corporation tax on Capital Gains arising from the sale of “qualifying participations “
Low income taxes on ancillary activities
Deductibility of accrued or paid borrowing costs.
Enhanced anonymity, confidentiality and transferability of shares through use of bearer shares |
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| Business Control Centre Company
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To Manage and administer international business operations
To Hold Intellectual Property or other corporate asset
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Reduction in Group corporate taxes – if 80% sales are derived from customer outside Switzerland preferential income rates apply
Exemption or reduction of income taxes on dividends from “qualifying participations”
Exemption or reduction of corporation taxes on Capital gains arising on the sale of “qualifying participations”
Deductibility of accrued and paid external and intra-group borrowing costs
Mixed Company
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| Swiss Finance Company/Subsidiary
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To fund group/ international operations
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Reduced corporation taxes on financial/interest income
Exemption or reduction on interest income from “qualifying participations”
Deductibility of accrued or paid borrowing costs including inter-group companies
Deductibility of Bad Debt Reserves of up to 10%
Deductibility of Realised Foreign Exchange Losses |
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Swiss Management Company |
Provision of management or services to non-Swiss entities
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Reduced (preferential) corporation taxes on income (7-10%)
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