Società holding a Zugo,
Svizzera
Il regime di esenzione sulla partecipazione svizzera elimina l’imposta sui dividendi per le partecipazioni qualificate. Combinato con il tasso effettivo dell’11,9% di Zugo e 96 convenzioni contro la doppia imposizione, una holding svizzera è una delle strutture più efficienti al mondo per i gruppi internazionali.
Perché una holding svizzera a Zugo?
Il regime svizzero di esenzione sulla partecipazione è uno dei più generosi al mondo — e Zugo lo amplifica con le aliquote cantonali più basse della Svizzera.
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.
Svizzera vs altre giurisdizioni 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.
Come impostare la tua holding svizzera a Zugo
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.
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.
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.
Come gli imprenditori internazionali usano le holding svizzere
Behind every Swiss holding is a founder who made a strategic decision. Here are three structures we see most often.
La struttura patrimoniale multigenerazionale
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.
La struttura holding pre-cessione
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.
La struttura commerciale internazionale
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.
Fondatori che hanno scelto la Svizzera per la loro holding
“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.”
“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.”
“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.”
Costruisci la tua holding svizzera passo dopo passo
Start with domiciliation and add services as your structure matures. No hidden fees.
- Official Zug registered address
- Mail delivered to your app
- Fiduciary certificate
- Handelsregister compatible
- Banking documentation
- Full AG formation
- CHE number within 5 days
- Commercial Register entry
- Participation exemption eligible
- 96 treaty network access
- Licensed Swiss resident director
- Substance for treaty benefits
- AML/KYC documentation
- Quarterly compliance
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.
Tutto ciò di cui la tua holding svizzera ha bisogno per operare.
FAQ: società holding svizzera
Stabilisci la tua holding svizzera a Zugo oggi
Indirizzo registrato attivo in 48 ore. Direttore svizzero, costituzione e supporto alla compliance disponibili. Garanzia soddisfatti o rimborsati 30 giorni.
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