Switzerland

Switzerland is chosen for reasons that have little to do with tax rates. It offers political and monetary stability measured in centuries, a legal system that behaves predictably, and a reputation that opens doors no offshore structure will open.

It is also expensive, demanding on substance, and unforgiving of companies that want the address without the presence.

The tax position

Switzerland taxes at three levels — federal, cantonal and communal — and the cantonal element varies enough that the same company can face materially different effective rates depending on where it is established. Cantons compete openly for corporate residents, and the choice of canton is a substantive planning decision rather than an administrative one.

The special regimes that once defined Swiss tax planning were abolished under the 2020 reform, replaced by measures available on equal terms to all companies, including patent box treatment and additional deductions for research and development. The effect was to make Switzerland more ordinary fiscally, and more durable internationally.

Participation relief remains significant: qualifying dividends and capital gains from substantial shareholdings receive relief that makes Switzerland a serious holding jurisdiction.

What it requires

Swiss companies require real presence. Local directors with actual authority, an office, and management that genuinely takes place in Switzerland — the requirement is enforced in practice, not merely stated.

Share capital must be genuinely paid in. Accounting obligations are strict, and audit is required above defined thresholds. Formation costs and annual running costs are considerably higher than in most European jurisdictions.

Banking

Swiss banks retain their reputation for competence and discretion, but discretion is no longer confidentiality: Switzerland participates fully in the automatic exchange of financial account information, and has done since 2017.

Onboarding is rigorous. Banks expect scale, a clearly documented source of wealth, and a relationship they regard as worth having. Minimum balances are substantial, and applications from clients below the bank’s threshold are declined without much discussion.

When it is the right choice

Switzerland suits businesses where reputation is commercially decisive, groups that want a stable headquarters jurisdiction, and substantial asset holding arrangements where cost is secondary to durability.

It is the wrong choice for a client seeking a low-cost incorporation, and we will say so directly rather than take the engagement.