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Knowledgebase

Benefits of a Holding Company in Switzerland

Alex Buri, Off-Counsel
16 May, 2025

Table of Contents

The Main Characteristics of Holding Companies in Switzerland

A holding company in Switzerland is a legal entity primarily established for the purpose of holding and managing equity interests in other domestic or international companies. These entities are typically structured as limited liability companies (GmbH) or joint stock corporations (AG), and their core economic function is the acquisition and control of shares in subsidiary businesses.

There are different types of holding companies that can be created in Switzerland, including pure holding companies and financial holding companies. A pure holding company is specifically organized for the long-term ownership and strategic management of subsidiaries. In order to be recognized as a pure holding structure, the company must derive at least two-thirds of its overall income and assets from these shareholdings. Additionally, a pure holding is not permitted to conduct any commercial activity within Switzerland. If the company generates income that is not classified as participation income, that income is subject to corporate taxation at the rate of 7.83%. Companies aiming to expand their market reach can consider Establishing a Branch in Switzerland, a strategic move for asset protection and operational flexibility.

Quick Facts About Swiss Holding Companies:

Category

Description

Legal entities used

Private limited liability company (GmbH), Joint stock corporation (AG)

Incorporation method

Registration with the Swiss Trade Register

Incorporation time

Approximately 12 weeks

Advantages

Fast registration, low corporate tax rates, access to double tax treaties

Precautions

Legal address in Switzerland required, cantonal laws must be respected

Shareholding structure

Minimum of one shareholder

Minimum capital

CHF 20,000 for GmbH, CHF 100,000 for AG

Taxation

Corporate tax ranges from 12% to 21%, depending on canton

Control

Full foreign ownership allowed

Accounting and reporting

Annual tax returns must be filed

Double taxation treaties

Approximately 80 treaties signed

Applicable legislation

Swiss Commercial Law

Types of holding companies available

Yes: operational, financial, organizational

Required documents

Statutory documents, shareholder and director details, proof of address, bank statement for share capital

Local director required

Yes, at least one natural person

Permitted uses

Share ownership, asset acquisition, IP ownership, control of companies

Need for local employees

No

Can operate internationally

Yes

Travel required for setup

Possibly, for actions like bank account opening

Holding company setup services

Yes, offered by local agents


One of the key reasons entrepreneurs and investors choose to form a holding company in Switzerland is the broad range of tax benefits this structure offers. The tax incentives are available both at the federal and cantonal levels, providing a powerful planning tool for corporate structuring. Furthermore, Switzerland has signed a significant number of double taxation treaties, which further enhance the tax efficiency of holding companies.

A Swiss holding company can also benefit from corporate tax exemptions on specific types of income, such as dividends, capital gains, and liquidation proceeds. To qualify for these exemptions, the holding company must typically hold at least 10% of the nominal share capital in the subsidiary that pays out the dividends, or the market value of the shareholding must exceed CHF 1 million.

In addition to managing equity investments, Swiss holding companies can also engage in other permissible activities such as intellectual property exploitation, debt financing, and issuing grants. However, these activities must remain secondary to the main objective of managing participations. Accounting, registration, and compliance services are readily available to facilitate the smooth functioning of holding structures in Switzerland.
Taxation of Swiss Holding Companies

Taxation of Swiss Holding Companies

The Swiss tax system is designed to favor holding companies, providing them with one of the most advantageous regimes in Europe. At the federal level, a Swiss holding company can benefit from a reduced corporate tax rate if it meets specific criteria, such as owning at least 20% of the share capital of another company or holding shares with a minimum market value of CHF 2 million.

Further tax relief is available if the holding company is structured with its principal purpose being long-term equity investments. Investors seeking to manage multiple subsidiaries can benefit from effective Company Formation in Geneva, taking advantage of Geneva’s favorable tax and regulatory environment. This requirement should be explicitly stated in the company's articles of association. Legal specialists in company registration can assist investors in drafting articles that meet this criterion and ensure eligibility for the tax exemptions.

Corporate income tax on capital is assessed at a flat rate of 7.8%. In addition, a corporate officer tax may be applied, ranging from 0.035% to 0.075% of the company’s capital base. Holding companies also benefit from Switzerland’s extensive network of double taxation agreements, which provide for reduced withholding tax rates on dividends, interest, and royalties.

To streamline cross-border trade operations, businesses should also consider EORI Registration in Switzerland, ensuring compliance with EU customs regulations.

These treaties can reduce the standard withholding tax rate from 35% to a significantly lower range, often between 5% and 15%. Moreover, agreements with EU countries under the EU Parent-Subsidiary Directive may provide full exemptions on dividends, further enhancing the attractiveness of the holding structure.

Specialized Swiss accounting firms are available to provide services such as compiling financial statements, maintaining compliance with reporting standards, and representing companies before tax authorities. Whether you need ongoing or one-time assistance, local professionals are prepared to support the fiscal needs of your Swiss holding company.
Contact us and get a consultation

Taxation at the Cantonal Level in Switzerland

Switzerland is composed of 26 cantons, each with its own authority to impose cantonal taxes, including those applicable to corporate entities. One of the most significant advantages of forming a Swiss holding company is the possibility of obtaining exemptions or reductions from cantonal income taxes. These tax benefits are granted under specific conditions, making the Swiss holding structure particularly attractive to international investors seeking tax optimization.

In general, Swiss holding companies are not liable to pay cantonal income taxes, provided that they meet the qualifying conditions established by the local tax authorities. The principal requirement for this tax exemption is that the company must derive at least two-thirds of its income from shareholding activities, including dividend income and capital gains from the sale of subsidiaries. Additionally, two-thirds of the company’s total assets must be comprised of shareholdings in other businesses.

If these criteria are fulfilled, the holding company is considered a non-operational entity in terms of cantonal tax obligations and may be granted full exemption from profit tax at the cantonal level. The exemption applies regardless of whether the income is generated domestically or internationally, provided the income stems from qualified participations.

These favorable cantonal tax rules contribute significantly to the popularity of the holding company structure in Switzerland, particularly for multinational corporations and high-net-worth individuals aiming to centralize their global shareholdings under a single tax-advantaged jurisdiction.

Adam Abdellaoui

Off-Counsel
+41 (44) 5152530
Taxation of Swiss Holding Companies in the Canton of Zug

Taxation of Swiss Holding Companies in the Canton of Zug

Among the 26 Swiss cantons, Zug stands out as one of the most attractive regions for establishing a holding company. Known for its pro-business environment and low tax rates, Zug has become a prime destination for investors looking to benefit from Switzerland’s favorable tax regime. In fact, statistics indicate that approximately one in four Swiss holding companies are registered in Zug. Swiss Shareholders play a critical role in managing equity structures and optimizing profit distributions within holding companies.

There are several reasons why Zug is a preferred location:
  • Cantonal tax exemptions
    Companies that meet the cantonal requirements for holding status may benefit from full exemption from cantonal income taxes.
  • Federal corporate tax rate
    The standard federal corporate income tax applicable in Zug is 8.5%, which is already competitive compared to other jurisdictions.
  • Exemptions on qualifying income
    Income or gains derived from qualifying participations (such as dividends from subsidiaries) may be exempt from corporate income tax.
  • Real estate investments
    Companies investing in real estate may benefit from treaty-based privileges under Switzerland’s network of double tax treaties.
These benefits make Zug a strategic base for holding companies that want to manage international subsidiaries while minimizing their tax liability. Investors choosing Zug can rely on expert guidance from company formation agents and tax advisors who understand the specific requirements of this canton.

Conditions for Obtaining Tax Exemptions on the Swiss Cantonal Tax

To access the generous cantonal tax exemptions available in Switzerland, holding companies must comply with clearly defined conditions. The most important of these conditions relates to the company’s purpose as stated in its articles of association. The primary business objective must be the long-term management of equity investments.

Key eligibility requirements include:
  • Main business activity: The company must focus exclusively or predominantly on the management of shareholdings in other companies.
  • Income and asset composition: At least two-thirds of the income and assets must be tied to participations.
  • Permissible secondary activities: While the core purpose is shareholding management, the company may engage in related activities such as holding or exploiting intellectual property, providing intra-group financing, or offering subsidies.
Legal and tax advisors specializing in Swiss company formation can ensure that the articles of association are drafted to align with the criteria for tax exemption. Proper structuring from the outset is essential to secure and maintain these benefits.

With the right planning, a Swiss holding company can enjoy long-term advantages, including significant reductions in tax liabilities and access to international tax treaties. These incentives continue to make Switzerland one of the most attractive jurisdictions for forming holding companies in Europe and globally.
Contact us and get a consultation

Why Open a Swiss Holding Company?

Establishing a Swiss holding company offers a wide array of benefits, particularly in terms of taxation. These benefits exist at both the federal and cantonal levels, making Switzerland one of the most desirable jurisdictions for setting up a holding structure. While the tax rates and exemptions at the cantonal level may vary, the federal treatment of holding companies remains consistent across the country.

One of the most compelling reasons to open a Swiss holding company is the participation exemption regime, which offers tax relief for income derived from participations in other companies. For holding companies with significant dividend income, understanding the Dividend Tax in Switzerland is essential for effective tax planning and profit maximization. Specifically, holding companies can benefit from exemptions on income such as dividends, capital gains, and passive earnings, provided they meet certain conditions.

Key tax benefits include:
  • Dividend exemptions: Dividends received from subsidiaries are exempt from corporate income tax if the holding owns at least 10% of the subsidiary’s shares or if the shareholding has a market value of at least CHF 1 million.
  • Capital gains exemptions: Gains from the sale of participations may also be exempt if the holding qualifies under the participation exemption regime.
  • No transfer taxes: Most holding companies are not subject to any transfer taxes on share transactions.
  • Deductible losses and interest: Holdings can deduct capital losses and interest expenses under certain conditions, providing additional financial flexibility.
  • EU Parent-Subsidiary Directive: Swiss holding companies can benefit from EU tax directive provisions when operating in EU jurisdictions, ensuring tax neutrality on cross-border dividend payments.
These features make the Swiss holding structure an optimal vehicle for consolidating global assets and managing international corporate ownership efficiently. This structure is particularly attractive for multinational enterprises, private equity firms, and high-net-worth individuals looking to streamline their holdings and reduce tax exposure.
Why Choose Switzerland as an Investment Destination?

Why Choose Switzerland as an Investment Destination?

Switzerland stands out as a premier investment destination due to its political stability, legal transparency, and robust economic performance. The country has cultivated an environment that supports entrepreneurial activity and long-term business growth.

Some of the key reasons why investors choose Switzerland include:
  • Extensive network of treaties: Switzerland has signed more than 100 bilateral investment protection treaties, which provide legal safeguards and favorable conditions for foreign investors.
  • Strong governance indicators: According to the OECD, Switzerland boasts a manager liability index of 5.0—on par with Germany—and a shareholder power index of 8.0, exceeding the OECD average.
  • Dominant sectors: In 2017, the finance and holding sectors represented 56.6% of all foreign direct investment in the country, underscoring the centrality of these sectors to the Swiss economy.
  • Greenfield investments: The country attracted 137 new greenfield investment projects, reflecting investor confidence in Switzerland’s market potential.
Switzerland’s well-developed financial infrastructure, multilingual workforce, and efficient public institutions further reinforce its status as an ideal location for setting up and operating holding companies. Investors can rely on a predictable regulatory environment and professional services in law, tax, and accounting to support their strategic objectives.

Conclusion

A Swiss holding company is more than a legal structure—it is a strategic financial tool for optimizing global ownership, minimizing tax liabilities, and safeguarding investments. With favorable treatment at both the federal and cantonal levels, along with access to an extensive network of double taxation and investment treaties, Switzerland offers one of the most compelling environments for international investors.

Whether you are a corporate group seeking to centralize control over subsidiaries, a private equity firm managing cross-border assets, or a foreign entrepreneur aiming for tax-efficient wealth structuring, Switzerland delivers both the legal framework and economic stability required for success. Partnering with local professionals ensures that your holding company is set up in compliance with all legal and tax regulations, allowing you to fully realize the benefits that this business structure has to offer.

Adam Abdellaoui

Off-Counsel
+41 (44) 5152530

FAQ – Benefits of a Holding Company in Switzerland

A legal entity for managing equity interests in other companies, often structured as a GmbH or AG.