Groups
Holding company
The Swiss holding at the centre of many structures: the participation deduction and treaty access, built on substance.
Holding companyInternational tax
structuring
Switzerland hosts holding, financing and IP functions efficiently: the participation deduction, the patent box, R&D relief and a wide treaty network. But the reliefs and treaty benefits now hold only with real substance and arm’s-length transfer pricing. We design structures that use the Swiss advantages correctly, build the substance they rely on, and document the pricing, so the outcome survives a foreign authority’s challenge, not just the first return.
At a glance
Efficient, and built to be defended openly.
Reliefs and treaties used correctly, with the substance to hold them.
- Holding
- Participation deduction
- IP
- Patent box, R&D super-deduction
- Cross-border
- Treaty network & EU agreement
- Condition
- Substance + arm’s-length pricing
- Large groups
- Pillar Two factored in
The essentials
What international structuring through Switzerland delivers
Switzerland offers a cross-border group an efficient, credible home for holding, financing and IP functions: the participation deduction, the patent box, R&D relief and a wide treaty network. The reliefs and treaty benefits are real, but conditional: they hold only where the Swiss functions are genuinely performed here and dealings are at arm’s length. Structuring is the work of using the advantages correctly while building the substance and pricing that make them defensible.
Who this is for
- groups placing a holding, financing or IP function in Switzerland;
- multinationals consolidating participations under a Swiss roof;
- innovation-led groups locating IP where the patent box applies;
- structures that must withstand foreign anti-avoidance scrutiny.
Where it fits
It builds on the effective-rate work, is confirmed by rulings, rests on substance, and for large groups runs alongside Pillar Two.
The building blocks
Holding, financing and IP
Three functions carry most international structuring through Switzerland. Each has a relief that makes it efficient and a condition that makes it hold.
| Function | The Swiss advantage | The condition |
|---|---|---|
| Holding | Participation deduction; treaties | Substance; beneficial ownership |
| Financing | Treaty network on interest | Thin-cap & safe-harbour rates |
| IP | Patent box; R&D super-deduction | DEMPE: IP managed here |
| All three | Stable, credible jurisdiction | Arm’s-length transfer pricing |
The advantages are genuine and the conditions are now strictly enforced: substance, beneficial ownership, the DEMPE functions for IP, and arm’s-length pricing throughout. A structure that takes the advantage without meeting the condition is the one that fails under challenge. We build both halves together.
The condition, made concrete
What substance must look like
“Substance” is not a slogan; it is people, decisions and premises that an auditor abroad can see. What each function actually has to show, in practice.
| Function | People & decisions | What fails |
|---|---|---|
| Holding | Board with real authority meeting in Switzerland | Decisions taken by the foreign parent |
| Financing | Treasury capacity; bears genuine risk | A conduit with no capital at risk |
| IP | DEMPE staff who develop and manage the IP | IP parked in Switzerland, run elsewhere |
The pattern behind every failure is the same: the income is booked in Switzerland but the decisions that earn it are taken somewhere else. A foreign tax authority, a treaty partner’s beneficial-ownership test, or a Pillar Two review then attributes the profit back. We size the substance to the value each function carries, enough that the structure holds, without paying for substance the structure does not need.
How it runs
From design to defensible structure
Design the structure, build the substance, set the pricing, confirm the position, in that order, so the efficiency rests on a foundation that holds.
- Stage 1
Functions & flows
Mapping what each entity will do and how value, dividends, interest and royalties flow across the group.
- Stage 2
Structure & reliefs
Designing the holding, financing and IP arrangements to use the participation deduction, patent box, R&D relief and treaties correctly.
- Stage 3
Substance & transfer pricing
Building the Swiss substance the functions require and setting arm’s-length pricing with documentation.
- Stage 4
Rulings & Pillar Two
Confirming key positions with cantonal and federal rulings, and factoring Pillar Two in for in-scope groups.
- Ongoing
Maintain & defend
Keeping substance, pricing and documentation current, ready to defend the structure openly if challenged.
Budget
What it costs
Structuring is scoped to the group: a single Swiss holding is lighter than a multi-function structure with financing, IP, transfer-pricing documentation and rulings across several jurisdictions. The substance and the documentation are real cost lines, because they are what make the structure hold.
We scope and quote against the functions and the flows. Pricing is on request.
Discuss your structure
What you need
What a structure requires
A structure that is both efficient and defensible rests on:
- genuine Swiss functions (holding, financing or IP) really performed here;
- substance proportionate to the profit booked in Switzerland;
- arm’s-length transfer pricing, set and documented;
- a treaty position that satisfies beneficial-ownership and anti-abuse tests;
- rulings on the material positions, and Pillar Two factored in for large groups.
A structure that works only on paper is now a liability
The single biggest change in international tax is that substance-light structures no longer work. They invite challenge. CFC rules, beneficial-ownership and principal-purpose tests, transfer-pricing adjustments and Pillar Two all probe whether Swiss profit is matched by Swiss activity. A structure designed purely for a low rate, with a letterbox and no real functions, is not a saving waiting to be enjoyed; it is an exposure waiting to be assessed by a foreign authority, often with penalties. We will not build one. We structure for genuine functions, defended openly — the only kind that holds.
Why Goldblum
Structuring, and what it involves
International structuring joins Swiss reliefs, the treaty network, substance, transfer pricing and Pillar Two. Building an efficient structure that survives challenge is the cross-border tax work this firm has done for groups since 2007.
Correct
Reliefs used properly
The participation deduction, patent box, R&D relief and treaties applied to genuine functions: the efficiency built on the rules, not around them.
Defensible
Substance and pricing that hold
The substance and arm’s-length transfer pricing built and documented, so the structure withstands a foreign authority’s scrutiny.
Current
Pillar Two and beyond
The structure designed for today’s anti-avoidance world, with Pillar Two factored in for in-scope groups from the start.
Related
What structuring connects to
Large groups
Pillar Two advisory
The 15% minimum tax that reshapes structuring for in-scope groups: scope, top-up and the substance carve-out.
Pillar TwoCertainty
Tax rulings
The advance confirmation that fixes a structure’s treatment with the authorities before capital moves.
Tax rulings
FAQ
International tax structuring: FAQ
01Why use Switzerland for international tax structuring?
Switzerland combines a competitive effective tax rate, the participation deduction on qualifying dividends and gains, a patent box and R&D relief, a wide double-tax-treaty network, and a stable, business-friendly legal system. For holding, financing and IP functions in a cross-border group, that mix can deliver a genuinely efficient and credible structure. The condition, and it is non-negotiable now, is real substance: the reliefs and treaty benefits only hold where the Swiss activity is genuine. We structure to use the advantages within that condition, not around it.
02What is the treaty network worth in a structure?
Switzerland's network of double-tax treaties, plus the agreement with the EU, reduces or eliminates withholding tax on cross-border dividends, interest and royalties, which is central to the after-tax efficiency of a holding or financing structure. But treaty benefits increasingly depend on substance and anti-abuse tests (beneficial ownership, principal-purpose tests), so a treaty cannot be relied on by a letterbox. We map the treaty position for the actual flows and ensure the structure has the substance to claim the benefits it is built on.
03How does a Swiss holding fit an international group?
A Swiss holding can sit above operating companies to consolidate participations, with the participation deduction bringing qualifying dividends and capital gains close to tax-free at the holding level, and the treaty network keeping dividend flows efficient. It suits a group wanting a credible, treaty-rich, stable jurisdiction for its holding function. The cantonal holding privilege was abolished in 2020, so the structure relies on the participation deduction and substance, not an exemption. We build the holding on the current rules, with the substance to make it respected.
04What about a Swiss financing or IP company?
Switzerland can host group financing and IP functions efficiently: interest and royalty flows benefit from the treaty network, the patent box reduces tax on qualifying IP income at cantonal level by up to 90 percent, and an R&D super-deduction can apply. But financing must respect thin-capitalisation and safe-harbour interest rules, and IP structures must reflect where the IP is genuinely developed and managed (the DEMPE functions). A financing or IP company without matching substance and arm's-length terms is the structure most exposed to challenge. We design both to hold.
05What is transfer pricing and why does it matter here?
Transfer pricing governs the prices charged between related companies (for goods, services, financing and IP) and it must be at arm's length, as if the parties were independent. Switzerland follows the OECD transfer-pricing guidelines. In a cross-border structure, transfer pricing determines how much profit each jurisdiction taxes, and tax authorities challenge prices that shift profit without matching substance and function. Defensible, documented transfer pricing is what makes a structure survive audit. We set and document the pricing as part of the structure, not as an afterthought.
06How much substance does an international structure need?
Enough that the Swiss functions are genuinely performed in Switzerland: real decision-making, people, premises and activity proportionate to the profit booked here. The standard has risen sharply: treaty anti-abuse rules, foreign controlled-foreign-company regimes, the OECD's substance focus and Pillar Two all test whether Swiss profit is matched by Swiss activity. A structure built for a low rate without the substance to support it is the one most likely to be unwound by a foreign authority. We size and build the substance to the functions the structure relies on.
07Will a foreign tax authority challenge a Swiss structure?
It can, and increasingly does, through CFC rules, beneficial-ownership and principal-purpose tests, transfer-pricing adjustments and substance enquiries. The era of structures that work on paper but not in substance is over. The defence is not secrecy; it is a structure with genuine substance, arm's-length pricing, proper documentation and, where useful, advance rulings. We build structures to be defended openly, because a structure that cannot withstand a foreign authority's scrutiny is a liability, not a saving.
08How does Pillar Two affect international structuring?
For groups in scope (consolidated revenue of at least EUR 750 million) Pillar Two floors the effective rate at 15 percent per jurisdiction, capping the benefit of a low Swiss rate and shifting the value to the substance-based carve-out and the location of real activity. Below that threshold, the full cantonal advantage and the reliefs remain available. So international structuring now has two regimes running in parallel, and we design for whichever applies to the group, taking the Pillar Two position into account from the start for in-scope structures.
09Is this still worth doing given all the anti-avoidance rules?
Yes, for genuine business structures with real substance. What has ended is artificial profit-shifting; what remains valuable is locating genuine functions in an efficient, stable, treaty-rich jurisdiction and using its reliefs correctly. A group that genuinely runs its holding, financing or IP from Switzerland, with substance and arm's-length pricing, still achieves an efficient and defensible outcome. The work is more demanding and more honest than it once was, which is why doing it properly matters. We structure for the substance-based world, not the one that has passed.
10What does Goldblum do on international tax structuring?
We design holding, financing and IP structures that use Swiss reliefs and the treaty network correctly, build and evidence the substance the structure relies on, set and document arm's-length transfer pricing, confirm key positions with rulings, and account for Pillar Two where the group is in scope. We work the structure to be defended openly under modern anti-avoidance rules. The aim is an efficient outcome that survives a foreign authority's challenge, not a paper saving that collapses under it.
Structuring a cross-border group?
Tell us the functions and the flows. A partner designs the Swiss holding, financing or IP structure with the substance and transfer pricing to make it efficient and defensible.