Is the Swiss holding regime still relevant after 2020?

Yes. After TRAF/STAF, participation exemption provides near-zero tax on qualifying dividends and capital gains, with OECD/EU compliance. Switzerland remains a top jurisdiction for holding structures.

Can a foreigner establish and own 100% of a holding in Switzerland?

Yes. 100% foreign ownership is allowed. At least one Swiss-resident director/authorized representative is required; professional director services are available.

What is the minimum share capital for a holding?

AG: CHF 100,000 (at least CHF 50,000 paid-in). GmbH: CHF 20,000 (fully paid-in). No special capital rules for holdings beyond standard AG/GmbH minimums.

What NOGA code is used for a holding company?

64.20 – Activities of holding companies. Assigned by the Swiss Federal Statistical Office based on the company’s stated purpose.

How did the BEPS reform affect Swiss holdings?

Special regimes ended; IIR applies from 1 Jan 2025 to groups with global revenue > EUR 750m. Participation exemption remains. Pillar Two top-up may apply if ETR <15%; ~99% of Swiss firms are below the threshold.

What documents are required for tax ruling applications?

Business plan or financials, evidence of participations, revenue/asset composition, purpose in articles, ownership chart with holding periods, and expense allocation method. Ruling typically in 4–8 weeks.

How does capital tax interact with corporate income tax?

Many cantons credit CIT against capital tax (0.001%–0.5%). Reductions often apply for equity tied to participations, intragroup loans, or patents, lowering the effective capital tax for pure holdings.

What are the audit requirements for Swiss holding companies?

Ordinary audit if 2 of 3 are met: assets ≥ CHF 20m, revenue ≥ CHF 40m, ≥ 250 employees. Smaller firms: limited audit; opt-out possible if <10 FTE and all shareholders agree.

Can a Swiss holding company conduct business activities?

It must avoid commercial operations. Ancillary activities (IP, intragroup loans, subsidies, certain real estate) are allowed, but if they exceed 2/3 of assets or income, holding status and benefits may be lost.

What is the timeline for opening a corporate bank account?

Typically 2–4 weeks. Banks require UBO IDs, source of funds, structure chart, business plan, certified incorporation docs, and board resolution. Tier-1 banks may have stricter KYC and longer timelines.

What are the substance requirements for treaty benefits?

Mind and management in Switzerland, Swiss-resident director, local office/secretariat, and robust documentation (minutes, contracts). Weak substance risks treaty benefit denial.

How does thin capitalization affect Swiss holdings?

Safe harbor for intragroup debt is generally up to 6:1 debt-to-equity. Excess may limit interest deductions. Financing and admin costs must be allocated between exempt and taxable income.

What are Controlled Foreign Company (CFC) rules in shareholder's jurisdiction?

Switzerland has no CFC rules. Shareholders may still face CFC taxation in their home countries; check local rules to assess shareholder-level tax impacts.

How do Pillar Two/IIR considerations affect holdings?

From 2025, groups with revenue > EUR 750m may owe top-up to reach 15% ETR. Example: 12% ETR implies a 3% top-up. Transitional safe harbors and QDMTT may reduce or eliminate liability.

What are common pitfalls to avoid?

Mixing operational activities, poor records, direct Swiss real estate ownership, and allowing IP/financing/services to dominate (exceed 2/3), which can forfeit holding status.

18.12.2025

Holding company in Switzerland: taxes, registration and benefits after the reform

Switzerland remains one of the world's premier jurisdictions for establishing holding companies in 2025, despite significant regulatory changes introduced by the TRAF (Tax Reform and AHV Financing) legislation.

Taxes in Switzerland

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