Ufficio virtuale Zugo per
strutture holding

L'esenzione di partecipazione svizzera, oltre 100 convenzioni contro la doppia imposizione e un'aliquota effettiva dell'11,9 % rendono Zugo la giurisdizione europea di riferimento per le holding internazionali. Il vostro indirizzo registrato stabilisce il fondamentale nexus svizzero.

Scopri la holding company Zugo Add-on analista finanziario
11.9% Aliquota effettiva (Baar)
100+ Paesi con convenzione fiscale
0% Plusvalenze su partecipazioni qualificanti
0% Ritenuta alla fonte su dividendi qualificanti
Vantaggio principale

Esenzione di partecipazione svizzera — Beteiligungsabzug

Under Swiss federal tax law, holding companies benefit from a participation reduction (Beteiligungsabzug) that effectively reduces tax on qualifying dividends and capital gains to near zero — one of the most powerful holding regimes in Europe.

Participation Exemption — Key Thresholds

To qualify for the Swiss participation relief, the holding company must meet the following conditions under Art. 69–70 DBG (Federal Tax Harmonization Act):

10%
Minimum participation in subsidiary (by capital or votes) to qualify for participation relief on dividends
CHF 1M
Alternative threshold — if market value of participation exceeds CHF 1 million, full exemption applies regardless of %
≥1 Year
Minimum holding period for capital gains exemption on sale of qualifying participations
0%
Effective tax on qualifying dividend income and capital gains after participation reduction is applied
Vantaggi fiscali

Perché Zugo è la principale giurisdizione holding d’Europa

Near-Zero Dividend Tax
Qualifying dividends received from subsidiaries benefit from near-complete Swiss tax exemption via the participation reduction. Combined with Zug's 11.9% nominal rate, effective tax on holding income can fall to under 0.5%.
Capital Gains Exemption
Capital gains from the sale of qualifying participations (held >1 year, >10% or >CHF 1M) are eligible for participation reduction — effectively 0% tax on exit gains. This is a significant advantage for group restructuring and M&A.
100+ Tax Treaty Network
Switzerland has signed double taxation agreements with over 100 countries. These treaties typically reduce or eliminate withholding tax on dividends, royalties, and interest flowing from subsidiaries to your Swiss holding — often to 0–5%.
AG Structure — Maximum Credibility
A Swiss AG (Aktiengesellschaft) offers bearer or registered shares, minimum capital of CHF 100,000, full legal personality, and is universally recognized by international banks and tax authorities. The preferred structure for holding companies.
Substance Requirements
A registered address combined with our resident director service provides the Swiss substance necessary to satisfy OECD BEPS guidelines and Swiss tax authority requirements. The Financial Analyst add-on further strengthens your substance footprint.
Low Cantonal Wealth Tax
Zug canton applies among the lowest wealth taxes in Switzerland. For holding structures, the effective wealth tax on company assets is a fraction of what other Swiss cantons charge — further reducing the overall group tax burden.
Convenzioni contro la doppia imposizione

Aliquote di ritenuta alla fonte secondo le convenzioni svizzere

Aliquote ridotte selezionate applicabili ai dividendi pagati da filiali a una holding svizzera qualificante.

Paese della filiale Ritenuta standard sui dividendi Aliquota secondo convenzione svizzera Struttura
Germany25%0% (qualifying holding)AG or GmbH parent
United States30%5% (10%+ holding)Swiss AG recommended
United Kingdom0%0%Post-Brexit treaty maintained
Netherlands15%0% (qualifying holding)AG or GmbH parent
France31.4%0–5%Minimum 10% participation
Singapore0%0%Strong treaty; low source tax
UAE0%0%2011 treaty; no source WHT
Hong Kong0%0%Comprehensive treaty 2014

Rates are indicative. Treaty qualification depends on ownership %, holding period, and entity type. Always verify with a qualified Swiss tax advisor.

Cosa offre VOZ

Le fondamenta della vostra holding svizzera

A registered address is the prerequisite for a Swiss holding company. Without a Zug address in the commercial register, your company cannot legally exist — and cannot access any of the tax advantages described above.

  • Legal registered address for AG or GmbH formation in Zug
  • Swiss resident director — satisfies substance requirements
  • Mail scanning for official communications from ESTV, tax office
  • Domiciliation certificate accepted by Swiss banks
  • Ongoing annual renewal — keep your holding active
Financial Analyst Add-on
Strengthen Your Swiss Substance

For holdings requiring demonstrable economic activity, our Financial Analyst add-on provides a qualified Swiss-resident analyst who reviews and signs off on your investment decisions — creating a documented Swiss nexus for strategic management functions.

  • Quarterly investment review documentation
  • Swiss-resident signatory on key decisions
  • Supports OECD BEPS substance requirements
Learn About Financial Analyst Add-on
IN PRATICA

Tre fondatori che hanno ristrutturato tramite Zugo. Cosa è cambiato.

Le strutture fiscali restano astratte finché non si vedono i numeri. Ecco cosa ha significato concretamente l’esenzione di partecipazione svizzera per tre aziende reali.

Hong Kong business district
Family Office · Hong Kong
Pagava il 25 % di tasse su ogni dividendo dalla sua filiale tedesca.
Robert had been running a German trading GmbH under a Hong Kong holding for nine years. Every dividend he pulled up to Hong Kong triggered 25% German withholding tax. His accountant had mentioned a Swiss structure once. He had ignored it.

After restructuring through a Zug AG, the same dividend triggered 0% withholding. The saving in year one covered his Swiss setup costs forty times over.
“I waited nine years to do this. That was nine years of unnecessary tax.”
— R.K., Family Office · Hong Kong
Germany → Swiss AG : 25% WHT → 0%
Technology startup
Fondatore tech · Francia
Ha venduto la sua quota per 4,2 M€. L’imposta sulle plusvalenze : 0 €.
Marc had spent four years building a SaaS company in France under a Swiss AG holding in Zug. His 35% stake was worth €4.2M at the Series B exit.

Under French law, that would have been a significant capital gains event. Under his Swiss holding structure — qualifying participation, held over 12 months — the gain was effectively exempt. Zero capital gains tax. On €4.2M.
“My Swiss structure cost me CHF 99/month for four years. The saving on exit was six figures.”
— M.D., SaaS Founder · France
€4.2M exit — ~0% capital gains
International group office
Struttura di gruppo · EAU
Quattro filiali. Quattro paesi. Una holding svizzera. Una fattura.
Fatima managed subsidiaries in Germany, Singapore, the Netherlands and the UK. Four sets of accountants. Four sets of dividend rules. Four tax bills every year.

After creating a Swiss AG in Zug as the group holding, all dividends flow to one address. All four source countries apply 0% withholding under their Swiss treaties. One annual tax return. One fiduciary. One place to manage everything.
“Zug simplified my entire group structure. I went from four tax headaches to one clean holding.”
— F.A., Group Director · UAE
4 countries → 0% WHT under Swiss treaties
TESTIMONIANZE

Fondatori che hanno costruito la loro holding svizzera con VOZ

RB

“The participation exemption is not theoretical — it is the reason I chose Switzerland. VOZ had my address ready in 24 hours. The AG formation took 8 days. UBS opened our account the following month.”

R.B.
Holding Director · Luxembourg
OM

“I moved from a Cyprus holding to a Swiss AG in Zug. Same treaty network, better reputation, lower effective tax rate. And no bank has ever questioned my Swiss structure.”

O.M.
Investment Manager · Israel
ST

“The Financial Analyst add-on was the piece I was missing. My German tax advisor needed documented evidence of Swiss substance. The quarterly investment reviews satisfied him completely.”

S.T.
Group CFO · Germany
PREZZI TRASPARENTI

Costruite la vostra holding svizzera passo dopo passo

Iniziate con l'indirizzo. Aggiungete sostanza quando ne avete bisogno.

Step 1
Domiciliation
CHF 99/month
+ CHF 59 one-time setup
  • Official Zug registered address
  • Mail delivered to your app
  • Fiduciary certificate
  • Handelsregister compatible
  • Banking documentation
Get Started →
Recommended
AG Formation
CHF 149 setup
+ CHF 100,000 share capital • CHF 0 notary (UBS)
  • Full AG formation & registration
  • CHE number within 5 days
  • Treaty-eligible structure
  • Participation exemption eligible
  • International bank recognition
Get Started →
Full Substance
Swiss Resident Director
CHF 3,000/year
+ CHF 249 one-time setup fee
  • Swiss-domiciled director in the Handelsregister
  • Individual signing authority (Zeichnungsberechtigung)
  • Satisfies Swiss residency requirement for AG/GmbH
  • Official correspondence & authority liaison
  • Annual renewal — director status maintained
Get Started →

Need maximum substance? Add our Financial Analyst service for documented Swiss investment decision-making.

COMPLETATE LA VOSTRA CONFIGURAZIONE

Tutto ciò di cui la vostra holding svizzera ha bisogno per operare

VOZ Vault
Encrypted Swiss storage for shareholder agreements, board resolutions, tax opinions, KYC documents.
Included with domiciliation
VOZ Docs
Board resolutions, shareholder agreements, power of attorney — generated in 30 seconds, 15 document types.
From CHF 12/month
VOZ AI Assistant
Unlimited Swiss tax, treaty and corporate law questions. Participation exemption, BEPS, WHT recovery.
CHF 12/month
VOZ Corporate
All-inclusive holding office — address, director, vault, docs and AI in one subscription.
CHF 699/month
Holding Company Zug Swiss Resident Director Add-on analista finanziario Swiss Bank Account
Domande

Domande frequenti

A registered address alone provides basic Swiss legal presence but may not satisfy full OECD BEPS substance requirements for treaty benefits. For holdings actively claiming treaty-reduced withholding rates, a Swiss-resident director (our Director service, CHF 3,000/year) is strongly recommended. Our Financial Analyst add-on further strengthens substance by documenting Swiss-based investment decision-making. The appropriate level of substance depends on the jurisdictions involved and the treaty benefits claimed.
A Swiss AG requires CHF 100,000 share capital, of which at least CHF 50,000 must be paid up at incorporation. For most holding structures, the AG is preferred over the GmbH due to its transferable share structure, bearer or registered share options, and broader international recognition by banks and tax authorities.
Switzerland levies 35% withholding tax on dividends paid by Swiss companies. Within a qualifying group structure, this can be reduced to 0% via the notification procedure (Meldeverfahren) — available when the Swiss parent holds at least 20% of the Swiss subsidiary and both entities are Swiss tax residents. For cross-border flows, treaty rates apply — often 0–5% for qualifying holdings. A qualified Swiss tax advisor should confirm the applicable procedure for your specific structure.
Yes. Non-Swiss nationals can own 100% of a Swiss AG or GmbH. There are no restrictions on foreign ownership of Swiss companies. However, at least one director or manager must be resident in Switzerland and have signing authority. Our Swiss Director service satisfies this requirement.
The Swiss participation exemption (Beteiligungsabzug) under Art. 69–70 DBG effectively reduces corporate tax on qualifying dividend income and capital gains to near zero. Qualification requires holding at least 10% of a subsidiary’s capital or votes, or shares worth CHF 1 million or more. For capital gains, a minimum holding period of 1 year applies. After the participation reduction, effective tax on qualifying holding income can fall below 0.5%.
Your registered Zug address is active within 48 hours. AG formation via Swiss notary takes 5–10 business days. Through our UBS partnership, notary fees are CHF 0 — you pay only the CHF 149 VOZ setup fee plus CHF 100,000 share capital. The entire process is 100% remote.
Switzerland has over 100 double taxation treaties. Key rates for qualifying holdings: Germany 0%, UK 0%, Netherlands 0%, Singapore 0%, UAE 0%, Hong Kong 0%, France 0–5%, USA 5%. These rates apply to dividends flowing from subsidiaries to a qualifying Swiss holding company. Always verify with a qualified Swiss tax advisor for your specific structure.
The Financial Analyst add-on provides a Swiss-resident qualified analyst who reviews and signs off on your investment decisions — creating documented evidence of Swiss-based strategic management. This strengthens your substance position under OECD BEPS guidelines and Swiss tax authority requirements, particularly for holdings claiming treaty-reduced withholding rates from multiple jurisdictions.
Strutturate la vostra holding

Ottenete oggi il vostro indirizzo holding svizzero

L'indirizzo registrato è il primo passo. Combinatelo con i servizi di costituzione e di direttore per costruire una struttura holding svizzera completa e fiscalmente efficiente.

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