Open a SPV Company in Switzerland

Switzerland has become an attractive destination for structuring Special Purpose Vehicles (SPVs), especially in the fields of securitisation, receivables management, and private investment structuring. Investors who want to open a company in Switzerland for such purposes often choose the SPV model due to its operational efficiency, legal flexibility, and favorable taxation. Before proceeding with the establishment of an SPV, it is crucial to complete the Company Registration process to ensure full legal compliance.

In this guide, we explore the legal foundations, types of corporate structures available, and the tax treatment of SPV companies in Switzerland as of 2025.

As of 2025, Switzerland does not have a separate SPV-specific law. Instead, SPVs are governed by general legal and regulatory provisions applicable to companies operating in the financial and securitisation sectors. Entities engaged in securitisation or debt issuance may also be subject to FINMA Supervision, particularly when handling large-scale investment transactions.

The two main sources of legal regulation include:

Importantly, since 1 January 2016, Switzerland has implemented the Financial Market Infrastructure Act (FMIA), which brought Swiss rules into closer alignment with EU financial directives, particularly:

These frameworks ensure transparency, investor protection, and facilitate cross-border financial transactions through standardized rules.

Investors looking to establish an SPV in Switzerland must select an appropriate legal structure. For those focusing on asset management and investment securitisation, forming an SPV in Zug offers additional benefits, such as favourable taxation and access to financial infrastructure. The two most commonly used corporate forms for SPV purposes are:

Each legal form has specific capital requirements, governance obligations, and reporting duties. Formation typically includes registration with the Swiss Commercial Register, drafting of articles of association, appointment of directors, and opening of a corporate bank account.

Swiss SPVs benefit from an efficient and competitive tax regime.
The key features include:

• Transfer of receivables: Generally exempt from transfer taxes. The sale or assignment of receivables does not trigger a tax liability.
• Value Added Tax (VAT): In most securitisation scenarios, the SPV is not subject to VAT when transferring receivables or debt instruments.
• Withholding tax: Interest payments made by a Swiss SPV are subject to Swiss withholding tax at a rate of 35%, unless reduced or exempted under a double taxation treaty.
• Capital gains tax: SPVs are generally taxed on capital gains; however, Switzerland permits the deduction of legitimate business expenses, which may reduce the overall taxable base.

Proper tax structuring is essential to benefit from double tax treaties, reduce withholding obligations, and optimise the fiscal outcome of SPV operations.

Switzerland offers a highly favourable jurisdiction for the formation and operation of SPVs — especially for securitisation, financing, and private investment transactions. With a stable legal environment, access to the European financial market, and transparent tax rules, the country continues to attract investors looking for a secure and compliant location for their SPV structures.

Foreign investors or fund managers seeking to open a Swiss SPV are encouraged to work with local legal and financial consultants who can provide tailored support on incorporation, licensing, and taxation. Companies dealing with distressed assets or debt collection may also need to coordinate with the Betreibungsamt, the Swiss debt enforcement office, during asset recovery operations.

For more information on forming a Swiss SPV, please consult with licensed company formation specialists.