Swiss Foundation
Establish a Swiss Foundation (Stiftung).
Tax-exempt. Perpetual. Zug-based.
A Swiss foundation (Stiftung) is a legal entity created by dedicating assets to a defined purpose under ZGB Art. 80–89a of the Swiss Civil Code. It has no shareholders, no members, no share capital. The founder transfers assets irrevocably to the foundation at creation. Charitable foundations qualify for federal and cantonal tax exemption under DBG Art. 56(g) upon ESTV approval. Switzerland hosts approximately 13,000 foundations. Goldblum & Partner AG, Baarerstrasse 25, Zug, provides the registered address, Stiftungsrat support, and end-to-end formation service.
ZGB Art. 80–89
Governing law
CHF 50k+
Typical endowment floor
Tax-exempt (charitable)
DBG Art. 56(g)
Perpetual structure
No fixed term
Key Data
Swiss Foundation — Key Facts
Stiftung: the vehicle for philanthropic and family wealth structures
CHF 50K
Minimum endowment capital
Dedicated assets must be irrevocably transferred to the foundation at incorporation.
6–8 wks
Typical formation time
Includes notarial deed, commercial register, and supervisory authority notification.
Tax-exempt
Status (if public benefit)
Foundations pursuing genuine public benefit purposes qualify for full tax exemption.
Federal/Cantonal
Supervisory authority
Swiss foundations are supervised by cantonal or federal authority depending on purpose.
Stiftung
Swiss foundation — key facts
and supervisory framework
Swiss Stiftung — specifications (ZGB Art. 80–89a)
Swiss foundations (Stiftung) are governed exclusively by the Swiss Civil Code (ZGB Art. 80–89a), not by the Code of Obligations (OR) which governs commercial companies. ZGB Art. 80: formation by dedicating assets to a defined purpose.
Inter vivos formation requires a notarial deed (öffentliche Urkunde) executed before a Swiss notary. Testamentary formation by will is also permitted. The foundation deed must state: name, domicile, purpose, endowed assets, and Stiftungsrat governance rules.
No statutory minimum under ZGB, but supervisory authorities expect an endowment sufficient to pursue the stated purpose. The widely cited practice floor is CHF 50,000. Formations below this level risk supervisory rejection or requests for additional capitalisation.
A foundation has no shareholders, no quotaholders, and no members. The founder transfers assets irrevocably to the foundation upon creation. No ownership rights are retained. The endowment cannot be reclaimed.
ZGB Art. 83: the Stiftungsrat is the supreme and sole governing body. Minimum one member legally sufficient; practice norm is at least three members. Fiduciary duties: duty of care, loyalty, and confidentiality. No explicit statutory Swiss-residency requirement for board members.
Foundations whose profit and capital are exclusively and irrevocably used for public benefit purposes are exempt from federal direct tax (DBG Art. 56(g)). Cantonal exemption under StHG Art. 23(f). Exemption is not automatic — separate application to ESTV (federal) and cantonal tax authority required.
Family and private-purpose foundations not qualifying for tax exemption are taxed at the general corporate rate. Zug combined effective CIT: 11.85% (federal + cantonal + municipal; KPMG Clarity 2024) — the lowest in Switzerland. Capital tax: 0.07% effective in Zug.
ESA (Eidgenössische Stiftungsaufsicht, edi.admin.ch) supervises foundations of national or international significance. Cantonal supervisory authority for locally-active foundations. Family and ecclesiastical foundations: simplified supervision (ZGB Art. 84 para. 2).
All Swiss foundations must register in the cantonal commercial register (Handelsregister) since the 2016 transparency reform. Entry is published in the FOSC (Swiss Official Gazette of Commerce) and searchable on Zefix (zefix.ch).
From notarial deed execution to full registration. Commercial register: 7–21 days. Supervisory authority review: 2–4 additional weeks. ESTV tax exemption application (charitable foundations): 3–6 months additional.
Charitable grant-making foundation
A philanthropist or family establishing a Swiss foundation for public-benefit purposes: education, research, arts, culture, poverty relief, or environmental protection. Must demonstrate to ESTV that the purpose genuinely serves the public interest (not a private group) to qualify for tax exemption under DBG Art. 56(g). Switzerland hosts approximately 13,000 foundations in the federal register — one of the deepest foundation ecosystems in the world.
Family succession and estate planning
A Swiss family foundation (Familienstiftung) is subject to ZGB Art. 335 restrictions: the purpose must cover costs of upbringing, establishment, support, or education of family members. It cannot be used for general wealth preservation or investment without a qualifying family-welfare purpose. This restriction is frequently misunderstood by founders from jurisdictions with broad private foundation laws (Liechtenstein, Austria). Professional legal advice is essential before formation.
IP holding and cultural preservation structure
A private-purpose foundation (no public-benefit tax exemption) used to hold intellectual property, maintain a specific cultural institution, or preserve a family collection. The purpose must be sufficiently defined in the foundation deed. A Zug-domiciled foundation benefits from the 11.85% combined CIT rate on any taxable income, and Goldblum & Partner AG at Baarerstrasse 25 provides the required Swiss registered address.
The irrevocability principle: what founders must understand before formation
ZGB Art. 80 establishes the defining characteristic of the Swiss foundation: once created and registered, the founder has no ownership rights over the endowed assets. They cannot be reclaimed, redirected to the founder, or used for purposes outside the foundation deed. This irrevocability makes the Swiss foundation the correct instrument for genuine succession planning, long-term philanthropy, and asset dedication — but it makes it unsuitable for temporary asset parking or structures where the founder expects to recover the assets. The foundation deed must clearly define the purpose; vague purposes are rejected by the supervisory authority. A reservation of revocation right at the time of creation is technically permitted under ZGB Art. 81 para. 2 but is rarely used in practice.
Formation process
Establishing a Swiss foundation.
From concept to registration.
Purpose Definition
1–2 weeks
Define the foundation's purpose precisely — charitable, family, or private. The purpose is irrevocable (ZGB Art. 80) and must be credible to the supervisory authority. Goldblum & Partner prepares a purpose memorandum and advises on charitable vs non-charitable qualification under DBG Art. 56(g).
Foundation Deed Drafting
1–2 weeks
Prepare the notarial deed (Stiftungsurkunde) per ZGB Art. 81: name, domicile, purpose, endowed assets, and Stiftungsrat (Foundation Board) governance rules. Goldblum & Partner drafts the deed for notary review. The deed must be executed before a Swiss notary.
Notary Appointment & Asset Transfer
1 week
Notarial deed executed before a Zug notary. Assets irrevocably transferred to the foundation (minimum CHF 50,000 in practice). Goldblum & Partner coordinates via power of attorney — no founder travel required.
Commercial Register & Supervisory Authority
2–5 weeks
Mandatory Handelsregister registration (all foundations since 2016 reform). Notification to the cantonal or federal supervisory authority (ESA for international-scope foundations). FOSC publication. ZEFIX entry live.
Tax Exemption Application
3–6 months
For charitable foundations: separate application to ESTV (federal direct tax exemption under DBG Art. 56(g)) and cantonal Steuerverwaltung. Goldblum & Partner prepares the application documentation. Exemption is granted retroactively from the date of foundation if approved.
Structure
Three types of Swiss foundation.
Purpose defines the structure.
Charitable Foundation
Gemeinnützige Stiftung
Purpose
Public benefit — education, research, arts, poverty relief, environmental protection
Tax
Exempt from federal and cantonal CIT (DBG Art. 56(g) + StHG Art. 23(f)) — application to ESTV required
Capital
CHF 50,000+ (practice floor, no statutory minimum)
Supervision
ESA (federal) or cantonal supervisory authority
On dissolution
Assets must go to another public-benefit entity — cannot return to founder
Best for
Philanthropists, family legacy institutions, international grant-making bodies
Family Foundation
Familienstiftung
Purpose
Limited to upbringing, establishment, support, or education of family members (ZGB Art. 335). Cannot be used for general wealth preservation or investment.
Tax
No automatic exemption — taxed at Zug combined rate (11.85%) unless charitable purpose demonstrated
Capital
CHF 50,000+ in practice
Supervision
Cantonal (simplified under ZGB Art. 84 para. 2)
On dissolution
Assets to designated beneficiaries or supervisory authority — not to founder
Best for
Multi-generational family support structures with genuine welfare purpose. NOT a private wealth vehicle.
Private Foundation
Privatnützige Stiftung
Purpose
Defined non-charitable purpose — maintaining a cultural institution, holding intellectual property, preserving a family collection, or operating a specific asset
Tax
Taxed at general corporate rate. Zug: 11.85% combined CIT. Capital tax: ~0.07%
Capital
CHF 50,000+ in practice
Supervision
Cantonal supervisory authority
On dissolution
Per deed — residual assets to named beneficiary or supervisory authority
Best for
IP holding, art collections, defined long-term asset dedication where company structure is unsuitable
Jurisdiction alert: the Familienstiftung is not a private wealth vehicle
The Swiss Familienstiftung is frequently misunderstood by founders from Liechtenstein, Austria, or common law jurisdictions where private foundations can function as general wealth vehicles. Under ZGB Art. 335, the family foundation purpose is narrow. For broad private wealth structures, a Swiss AG combined with a discretionary trust may be more appropriate. Goldblum & Partner advises on the correct structure before formation.
FAQ
Frequently asked
questions
Precise answers to the most common questions about forming a company in Switzerland. For specific advice on your structure, book a free consultation.
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Baarerstrasse 25 · 6300 Zug · Switzerland · Est. 2007