Swiss Holding Company: Setup and Tax Guide

Marcus Altenburg, Managing Partner Published 07 Nov 2026

A Swiss holding company is an ordinary Swiss corporation, usually an AG or GmbH, that owns participations in other companies. Switzerland no longer grants the former cantonal holding-company tax status; that privilege ended when STAF took effect on 1 January 2020. The main tax relief now is the participation deduction for qualifying dividends and capital gains. The company must be formed under ordinary company law, and its tax position depends on its actual participations, income and activities.

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Holding company formation

Formation and structuring of a Swiss holding company, including company form, participations and tax position.

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What a Swiss holding company is

A Swiss holding company is a company used to own shares or other participations in subsidiaries or related businesses. It may also provide group services or financing if its constitutional purpose and operating arrangements support those activities. “Holding company” describes the company's role; it is not a separate form of company under Swiss law.

The two common forms are the Aktiengesellschaft (AG) and the Gesellschaft mit beschränkter Haftung (GmbH). The AG has shares and a board of directors. A GmbH has members and quotas, with company-law rules suited to a more closely held ownership structure. Both forms can be used as a holding vehicle. The choice should take account of ownership transfers, governance, investor expectations and future transactions.

For a broader comparison of the two forms, see our guide to AG versus GmbH in Switzerland.

Company capital and representation

A Swiss holding company must meet the capital and representation rules of its chosen legal form. As of November 2026, the Code of Obligations sets the following minimum share capital:

Company-law capital minima as of November 2026
Form	Minimum share capital	Amount paid in at formation
AG	CHF 100,000	At least CHF 50,000 and 20 per cent of each share
GmbH	CHF 20,000	CHF 20,000 in full

The AG rules appear in Articles 621 and 632 CO; the GmbH capital minimum and full-payment rule appear in Articles 773 and 777c CO. The company must also be able to be represented by at least one person resident in Switzerland (AG: Art. 718 para. 4 CO; GmbH: Art. 814 para. 3 CO). The resident representative's role and authority should be documented in the articles and corporate records.

Tax treatment and the participation deduction

A Swiss holding company is subject to ordinary federal, cantonal and communal corporate taxation. The former cantonal holding, domiciliary and mixed-company privileges were abolished by the Federal Act on Tax Reform and AHV Financing (STAF/TRAF) with effect from 1 January 2020. A company does not obtain a blanket tax exemption merely because its purpose is to hold participations. The Federal Tax Administration's note on tax harmonisation describes the removal of the former privileges.

As of November 2026, the main holding-company relief is the participation deduction under Articles 69–70 of the Federal Direct Tax Act (DBG). For dividend income, it generally applies if the recipient holds at least 10 per cent of the distributing company's share capital or profit and reserves, or if the participation has a fair market value of at least CHF 1 million. The deduction reduces tax in proportion to net participation income; it does not exempt all of the company's other income.

A capital gain on a participation has a separate condition. As of November 2026, the seller generally needs a participation of at least 10 per cent and a holding period of at least one year. Tax treatment can also depend on acquisition cost, transaction form and the relevant cantonal rules. The participation deduction and broader corporate tax position are discussed in our Swiss corporate tax guide.

Switzerland's cantons set their own corporate tax rates within the federal framework. Canton selection should therefore follow a realistic view of where the company will be managed, what activity it will perform, how profits arise and which reliefs actually apply. A low headline rate alone does not establish a favourable tax outcome.

Setting up a Swiss holding company

A Swiss holding company is incorporated through the ordinary formation process for an AG or GmbH. The work usually follows this sequence:

Define the holding purpose, planned participations, group services and source of funds.
Select the legal form, company name, seat and governance arrangements.
Prepare the articles, incorporation documents, ownership information and director appointments.
Arrange the capital contribution and execute the incorporation deed before a Swiss notary.
File the company with the commercial register, then complete tax, accounting and banking setup.

As part of the incorporation plan, check whether the company's articles match its actual work and whether the group arrangements are documented on an arm's-length basis. Goldblum and Partners can help with Swiss holding company formation, the choice between an AG and GmbH, and the initial tax structuring.

When this does not apply

A Swiss holding company is not a substitute for a regulated financial institution where the activity requires authorisation, and it does not automatically qualify for the participation deduction if its investments miss the statutory conditions. A company that performs substantial operating activities may still own subsidiaries, but its financing, substance and tax treatment should be assessed as an operating group rather than assumed to follow a pure holding model.

Primary sources: Code of Obligations (CO) · Federal Direct Tax Act (DBG) · Tax Harmonisation Act (StHG) · Federal Tax Administration (FTA)

FAQ

Frequently asked questions.

Is a Swiss holding company a separate legal form?

No. A Swiss holding company is an ordinary Swiss company, commonly an AG or GmbH, whose purpose includes holding participations in other companies. The label does not create a separate legal form or a special tax status.

What share capital does a Swiss holding company need?

As of November 2026, a Swiss AG has registered share capital of at least CHF 100,000, with at least CHF 50,000 and at least 20 per cent of each share paid in at formation. A GmbH has at least CHF 20,000 of share capital, fully paid in. These are company-law capital requirements, not formation fees.

Does Switzerland still have a special holding-company tax status?

No. The cantonal holding-company tax privilege was abolished from 1 January 2020 under the Federal Act on Tax Reform and AHV Financing (STAF/TRAF). Swiss holding companies are taxed under the ordinary corporate tax system and may qualify for the participation deduction.

When does the participation deduction apply to dividends?

As of November 2026, the federal participation deduction for dividend income generally requires a holding of at least 10 per cent of the other company's share capital or profit and reserves, or a participation with a fair market value of at least CHF 1 million. The deduction reduces profit tax in proportion to qualifying net participation income; it is not a blanket exemption from tax.

Can a Swiss holding company claim relief on a capital gain?

As of November 2026, a capital gain may qualify for the federal participation deduction where the seller held at least 10 per cent of the other company's share capital or profit and reserves and held the participation for at least one year. The statutory conditions should be checked against the transaction and the current tax rules.

How do I set up a Swiss holding company?

Choose whether an AG or GmbH fits the ownership and governance needs, define the company's purpose and seat, appoint a person resident in Switzerland who can represent it, prepare the incorporation documents, pay in the required capital, execute the public deed and file for commercial-register entry. Tax and banking steps should be coordinated with the planned group structure.

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