Switzerland — Canton Zug

Holding Company in Zug,
Switzerland

Switzerland’s participation exemption eliminates dividend tax on qualifying holdings. Combined with Zug’s 11.9% effective corporate rate and 96 double taxation treaties, a Swiss holding is one of the world’s most efficient structures for international groups.

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0%
Dividend tax (participation exemption)
11.9%
Effective Zug corporate rate
96
Double taxation treaties
CHF 100k
AG share capital
Swiss Tax Advantages

Why a Swiss Holding Company in Zug?

The Swiss participation exemption regime is one of the most generous in the world — and Zug amplifies it with the lowest cantonal rates in Switzerland.

Participation Exemption (0% Dividend Tax)

When a Swiss company holds at least 10% of the capital of a subsidiary (or shares worth CHF 1M+), dividends received are effectively exempt from Swiss corporate income tax. Capital gains on sale of qualifying stakes are similarly exempt.

Cantonal Tax Holiday

New holding companies in Zug may apply for a temporary cantonal tax exemption (Steuerbefreiung) for up to 10 years, subject to cantonal approval and economic substance requirements. Applicable for qualifying start-up holding structures.

96 Double Taxation Treaties

Switzerland has one of the world's most extensive treaty networks. Dividends, interest, and royalties paid from treaty countries to a Swiss holding benefit from significantly reduced withholding taxes 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 and communal taxes and receive a full federal reduction. Effectively zero capital gains tax on most subsidiary sales.

No CFC Rules

Switzerland does not have controlled foreign corporation (CFC) rules. Income retained in foreign subsidiaries is not attributed to the Swiss holding on a look-through basis, providing planning flexibility unavailable in the EU.

Stable Political & Legal Environment

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

The Process

How to Set Up Your Swiss Holding in Zug

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.

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. The process takes 5-10 business days.

3

Obtain 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.

Frequently Asked Questions

Swiss Holding Company FAQ

Under Swiss corporate tax law (DBG Art. 69), a Swiss company that holds at least 10% of the share capital or voting rights of another company, or shares with a fair market value of at least CHF 1,000,000, benefits from a proportional reduction in cantonal and federal income tax equal to the ratio of qualifying dividend income to total income. In practice, for a pure holding company receiving only qualifying dividends, the effective tax on those dividends approaches zero.
No. Foreign nationals can be shareholders of a Swiss AG or GmbH without restriction. However, for a GmbH with non-resident managers, at least one manager authorised to sign for the company must be resident in Switzerland. For an AG, at least one member of the board of directors with signing authority must be resident in Switzerland. VOZ provides this residency requirement through our Swiss director service.
Canton Zug can grant newly established or relocated companies an exemption from cantonal and communal income and capital taxes for up to 10 years. The exemption is available for companies that create new jobs in the canton or bring new activities. Applications are submitted to the Zug cantonal tax authority (Steuerverwaltung Zug). Eligibility and duration depend on the company's economic substance and activity plan. Federal tax is never exempted under this scheme.
Yes. Swiss holdings can own shares in foreign property-holding companies, which is the standard structure for international real estate portfolios. Direct ownership of foreign real estate by a Swiss holding is also possible, subject to the tax rules of the country where the property is located. Swiss participation exemption does not apply to income from direct foreign real estate but applies to dividends from foreign property companies where the 10% threshold is met.
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