Suisse — Canton de Zoug

Société holding à Zoug,
Suisse

Le régime d’exonération participative suisse supprime l’impôt sur les dividendes pour les participations qualifiées. Combiné au taux effectif de 11,9 % de Zoug et aux 96 conventions de double imposition, une holding suisse est l’une des structures les plus efficaces au monde pour les groupes internationaux.

0%
Impôt sur dividendes
0%
Taux IS à Zoug
0
Conventions CDI
Including USA, UK, Germany, France, China, Japan, UAE, Singapore and 90+ more
CHF 100k
Capital social AG
Avantages fiscaux suisses

Pourquoi une société holding suisse à Zoug ?

Le régime suisse d’exonération participative est l’un des plus généreux au monde — et Zoug l’amplifie avec les taux cantonaux les plus bas de Suisse.

Participation Exemption (0% Dividend Tax)

Dividends received from a subsidiary where the Swiss holding owns 10%+ of capital (or shares worth CHF 1M+) are effectively exempt from Swiss corporate income tax. This applies at both federal and cantonal level.

Cantonal Tax Holiday

New holding companies in Zug may apply for a temporary cantonal tax exemption for up to 10 years, subject to cantonal approval and demonstrated economic substance. Federal tax (8.5%) still applies during the holiday.

96 Double Taxation Treaties

Switzerland has one of the world's most extensive treaty networks. Dividends, interest, and royalties from treaty countries flow to a Swiss holding with significantly reduced withholding at source.

Capital Gains on Qualifying Stakes

Gains on disposal of a qualifying participation (10%+ or CHF 1M+, held for at least 1 year) are exempt from cantonal taxes and receive a full federal reduction. Effectively zero capital gains tax on most subsidiary exits.

No CFC Rules

Switzerland has no controlled foreign corporation rules. Income retained in foreign subsidiaries is not attributed to the Swiss holding on a look-through basis — providing planning flexibility unavailable in most EU jurisdictions.

AAA Sovereign Stability

Switzerland's AAA-rated political stability, neutral stance, and top-3 rule-of-law ranking make it the jurisdictional choice when certainty over decades matters more than marginal tax optimisation.

Comparatif de juridictions

Suisse vs autres juridictions holding

How Zug compares to the Netherlands, Luxembourg, Cyprus and BVI on every factor that matters for international holdings.

Factor Switzerland (Zug) Netherlands Luxembourg Cyprus BVI
Dividend tax 0% (participation exemption) 0% (deelnemingsvrijstelling) 0% (PEX) 0% 0%
Capital gains ~0% qualifying ~0% ~0% ~0% 0%
Corporate tax 11.9% 25.8% 17% 12.5% 0%
Tax treaties 96 100+ 80+ 65+ None
OECD reputation Excellent Excellent Good Under pressure Poor
Banking access Excellent Good Good Difficult Very difficult
Substance requirements Low–Medium Medium High Medium High
Crypto friendly Excellent Moderate Moderate Low Low

Tax rates are effective combined rates for 2025. Sources: Swiss Federal Tax Administration, cantonal tax offices, KPMG Clarity on Swiss Taxes.

Le processus

Comment créer votre holding suisse à Zoug

1

Domiciliation Address

Start with a VOZ registered address in Zug. This provides your commercial register address and physical presence for Swiss tax residency purposes. Active within 48 hours, fully remote.

2

Incorporate (AG or GmbH)

Work with a Swiss notary to incorporate your holding vehicle. An AG (CHF 100,000 share capital) is preferred for holdings with multiple shareholders or future investors. Through our UBS partnership, notary fees are CHF 0. Commercial register entry in 5–10 business days.

3

Swiss Director (Optional)

For tax treaty benefits and substance, a Swiss-resident director is recommended. Our director service provides a qualified professional director based in Zug — satisfying the legal residency requirement without you relocating.

Structures réelles

Comment les entrepreneurs internationaux utilisent les holdings suisses

Behind every Swiss holding is a founder who made a strategic decision. Here are three structures we see most often.

Family Office

La structure patrimoniale transgénérationnelle

A Singapore-based entrepreneur sold his tech company for USD 12M. He needed a structure to hold investment assets across 4 jurisdictions, receive dividends tax-efficiently, and pass wealth to his children with minimal friction.

Solution: Swiss AG holding in Zug. Participation exemption on all subsidiary dividends. 96 tax treaties covering his assets in the US, UK, Germany and Singapore. Director service providing Swiss substance.

0% dividend tax on qualifying distributions
Tech Founder

La structure holding pré-cession

A French SaaS founder with operations in France and the UK restructured before a Series B. Investors expected a clean, tax-efficient holding structure. A UK HoldCo was too expensive. Luxembourg required substance he couldn’t provide.

Solution: Swiss GmbH holding in Zug. Capital gains on qualifying stake sale effectively 0%. Clean structure recognized by US and European VCs. Active within 5 business days.

~0% capital gains on qualifying stake sales
Trading Group

La structure de négoce international

A Dubai-based commodities trader needed a Swiss entity to receive trading profits from subsidiaries in 4 countries. His existing offshore structure was creating banking problems — no Swiss bank would open accounts for BVI entities.

Solution: Swiss AG in Cham, Zug. Treaty-reduced withholding on dividends from German and French subsidiaries. UBS account opened within 3 weeks. Fully OECD-compliant structure.

96 treaties — reduced withholding at source
Témoignages

Fondateurs qui ont choisi la Suisse pour leur holding

R

“I restructured from a Cyprus holding to a Swiss AG in Zug in six weeks. The participation exemption alone saves me over CHF 80,000 per year in dividend tax. VOZ handled the address and director — my Swiss lawyer handled the formation. The cleanest structure I have ever had.”

R.K. — Holding Director
Hong Kong · AG, Canton Zug
S

“My VC insisted on a Swiss HoldCo before leading our Series A. VOZ had the Zug address live in 24 hours, and the formation was complete before our term sheet expired. The 96 treaty network was the deciding factor over Luxembourg.”

S.M. — Tech Founder
France · GmbH Holding, Zug
O

“After 12 years of using an offshore structure that created constant banking headaches, switching to a Swiss holding in Zug was transformative. UBS opened our account in three weeks. Every counterparty we deal with recognizes and respects the Swiss structure.”

O.B. — Family Office
UAE · AG Holding, Cham
Tarifs transparents

Construisez votre holding suisse étape par étape

Start with domiciliation and add services as your structure matures. No hidden fees.

Start — Domiciliation
CHF 99/mo
+ CHF 59 one-time setup fee
  • Official Zug registered address
  • Mail delivered to your app
  • Fiduciary certificate
  • Handelsregister compatible
  • Banking documentation
Get Started →
Recommended
Build — AG Formation
CHF 149 setup
+ CHF 100,000 share capital · CHF 0 notary (UBS partnership)
  • Full AG formation
  • CHE number within 5 days
  • Commercial Register entry
  • Participation exemption eligible
  • 96 treaty network access
Get Started →
Complete — Swiss Director
CHF 3,000/year
Ongoing annual fee
  • Licensed Swiss resident director
  • Substance for treaty benefits
  • AML/KYC documentation
  • Quarterly compliance
Get Started →

Start with domiciliation only and add formation when your structure is ready. Most holding clients activate the address first, then form the AG within 30–90 days.

Outils numériques pour structures holding

Tout ce dont votre holding suisse a besoin pour fonctionner.

VOZ AI Assistant
Unlimited Swiss tax, treaty and corporate law questions. Ask about participation exemption, withholding recovery, CFC rules.
CHF 12/month
Learn more →
VOZ Vault
Encrypted Swiss storage for shareholder agreements, board resolutions, tax opinions and KYC documents.
From CHF 12/month
Learn more →
VOZ Docs
Generate board resolutions, shareholder agreements, power of attorney and compliance reports in 30 seconds.
From CHF 12/month
Learn more →
VOZ Corporate
All-inclusive holding office — address, director, vault, docs and AI in one subscription.
CHF 699/month
Learn more →
Questions fréquentes

FAQ : société holding suisse

The Swiss participation exemption means that dividends received by a Swiss company from a subsidiary are effectively tax-free when the Swiss company holds at least 10% of the subsidiary's share capital, or shares worth CHF 1 million or more. Capital gains on disposal of qualifying stakes (held for at least 1 year) are similarly exempt from cantonal taxes and receive a full federal reduction. This makes Switzerland one of the most efficient holding jurisdictions in the world.
No. Non-residents can own 100% of a Swiss holding company. However, Swiss law requires at least one Swiss-resident director or manager for GmbH and AG structures. Our Swiss Director service satisfies this requirement — enabling a full Swiss structure without you relocating.
New holding companies in Zug may apply for a temporary cantonal tax exemption (Steuerbefreiung) for up to 10 years. This is subject to cantonal approval and economic substance requirements — the company must demonstrate genuine activity rather than passive holding only. The federal corporate tax (8.5%) still applies during the holiday. We recommend a tax opinion before relying on this exemption.
Yes. A Swiss holding company can own shares in foreign property-holding entities or direct real estate in jurisdictions that permit foreign ownership. Swiss tax treatment of foreign real estate depends on the applicable double taxation treaty. In many cases, foreign real estate income is exempt from Swiss tax under the exemption method.
A Swiss AG requires CHF 100,000 share capital, of which at least CHF 50,000 must be paid up at incorporation. A GmbH requires CHF 20,000. For holdings with multiple shareholders or future investors, the AG is preferred due to its transferable share structure.
Your registered Zug address is active within 48 hours. GmbH or AG formation takes 5–10 business days via Swiss notary. Through our UBS partnership, notary fees are CHF 0 — you only pay the CHF 149 VOZ setup fee. The entire process is 100% remote.
No. Switzerland has no CFC rules. Income retained in foreign subsidiaries is not attributed to the Swiss holding on a look-through basis. This provides significant planning flexibility unavailable in most EU jurisdictions.
A registered Zug address starts at CHF 99/month with a CHF 59 one-time setup fee. AG formation requires CHF 100,000 share capital plus CHF 149 VOZ setup fee (notary fees CHF 0 via UBS partnership). Swiss Director service is CHF 3,000/year. 30-day satisfaction guarantee.
Commencer votre structure

Créez votre holding suisse à Zoug dès aujourd’hui

Adresse enregistrée active en 48 h. Directeur suisse, constitution et accompagnement compliance disponibles. Garantie satisfait ou remboursé 30 jours.

Garantie 30 jours · CHF 59 mise en place · résiliable à tout moment