Switzerland CFC rules

[A1988]

You can try moving to a low-tax canton?

Thanks, which one? Apparently someone told me switzerland might not work

 

[Marzio]

Where do you think is best to have IP holding company in europe then? Holland, luxembourg, Malta?

Switzerland is less than 3 hr drive to my R and D company in italy

If you take into account both those statements i guess this option will be veeeeery interesting for you.

https://www.offshorecorptalk.com/threads/any-good-setups-in-switzerland.30453/page-4#post-163441
Company in Liechtenstein and tax residency in Switzerland.

I haven't checked the actual DTT between Liechtestein adn Switzerland so i don't know if the loophole @JustAnotherNomad is talking about is really a thing.

 

[JustAnotherNomad]

I spoke about that with a Swiss tax lawyer and he said it's not true. However, the Swiss lawyer seemed to be very conservative and not interesting in creative solutions.
I would talk to a couple tax lawyers from Liechtenstein maybe and then verify the information with a Swiss lawyer afterwards...

 

[Marzio]

I spoke about that with a Swiss tax lawyer and he said it's not true.

Maybe it wasn't entirely true but surely there's something about it.

Read article 23.2

https://www-fedlex-admin-ch.transla...x_tr_sl=de&_x_tr_tl=en&_x_tr_hist=true#art_23

 

[A1988]

If you take into account both those statements i guess this option will be veeeeery interesting for you.

https://www.offshorecorptalk.com/threads/any-good-setups-in-switzerland.30453/page-4#post-163441
Company in Liechtenstein and tax residency in Switzerland.

I haven't checked the actual DTT between Liechtestein adn Switzerland so i don't know if the loophole @JustAnotherNomad is talking about is really a thing.

Very interesting, will look into it, at the moment i am keen on Malta for personal tax residency and cyprus holding company which allows me 2.5% on qualifying IP income with no withholding tax on distribution of income. Dividends received in Malta is tax free or non dom basis will reduce my tax bill significantly and allows me 0% on sale of my company, money realised is not remitted into malta

 

[Marzio]

You will pay significantly more in CH so if you don't care about living in CH and / or being near your R&D then the Malta + Cyprus option will be surely cheaper.

 

[A1988]

You will pay significantly more in CH so if you don't care about living in CH and / or being near your R&D then the Malta + Cyprus option will be surely cheaper.

Its the same thing time wise, from Switzerland i will be driving to bologna and from Malta i will be taking a flight. Malta has better weather though, I don't care about living in switzerland honestly, its a overpriced country plus I am not employed by any swiss company so it doesnt matter in my case, i was only looking from an optimisation point of view, I would only use their banking system though, as they say USE the good things the country has to offer

 

[Marzio]

I would only use their banking system though, as they say USE the good things the country has to offer

I heard Credit Suisse is was very good....

 

[A1988]

I heard Credit Suisse is was very good....

Lol yes, but honestly if you have some spare money i cant think of any place other than switzerland or luxembourg for offshore banking with 6 digits?

 

[Marzio]

if you have some spare money i cant think of any place other than switzerland or luxembourg for offshore banking with 6 digits?

Yes i was joking but Switzerland, beside Credit Suisse reckless management, is still one of the safest places for offshore banking on par with Singapore.