Swiss Holding Company
Swiss holding AG in Zug.
Participation exemption. 11.85% rate.
A Swiss AG in Zug is the standard holding vehicle for international groups, family offices, and crypto treasury structures. Dividends from qualifying participations (≥10%) are effectively tax-exempt via the participation exemption (DBG Art. 69). The 11.85% Zug rate applies to retained income. Shareholders remain private — not listed in ZEFIX.
11.85%
Zug combined CIT
≥10%
Participation exemption threshold
90%
Patent box IP relief
Private
Shareholder register
Key Data
Swiss Holding Company — Tax Benefits
Key figures for holding structures in Switzerland
≥10%
Min. shareholding for exemption
Or CHF 1M fair market value — whichever is reached first (DBG Art. 69).
~0%
Effective tax on qualifying dividends
Participation exemption reduces corporate tax to near zero on qualifying holdings.
90%
Patent box income reduction
Qualifying IP income reduced by up to 90% at cantonal level (StHG Art. 24a).
11.85%
Zug corporate tax rate
Combined federal + cantonal + municipal. Lowest major canton in Switzerland.
Holding Structure
Swiss holding company — key facts
and tax framework
Swiss holding AG — specifications
Shareholder privacy (not in ZEFIX), free share transfer without notarisation (OR Art. 684), eligible for IPO — all advantages for holding structures. GmbH possible but uncommon for international holding chains.
Of which CHF 50,000 paid-in at incorporation (OR Art. 621, 632). Capital may be denominated in USD, EUR, or GBP since the 2023 OR revision.
Post-STAF (2020) rate. The cantonal holding privilege (Holdingprivileg) was abolished — all Swiss holding companies are now taxed at the general cantonal rate. Zug remains lowest at 11.85%.
Dividends and capital gains from participations of ≥10% ownership (or ≥CHF 1M fair market value) are effectively exempt from federal and cantonal corporate tax. Holding period for capital gains: ≥1 year.
Federal withholding tax (VStG Art. 13) on dividends distributed to foreign shareholders. Reduced under 100+ Swiss DTTs — typically to 0–15% depending on jurisdiction and shareholding threshold.
At least one board member with signing authority must be domiciled in Switzerland. Goldblum & Partner provides nominee director services.
Global 15% minimum tax applies only to MNE groups with consolidated revenue exceeding EUR 750M. Does not affect the majority of international holding structures using Zug AG.
Qualifying net IP income can be reduced by up to 90% at the cantonal level. Zug holding structures used for IP ownership benefit from this relief alongside the participation exemption.
International group holding
A Zug AG as the intermediate or top-level holding vehicle for an international group of subsidiaries. Dividends flow up tax-efficiently via the participation exemption. The 11.85% rate applies to any retained operating income at the holding level.
Crypto & fintech treasury
Swiss holding AG as the group's treasury company for crypto protocols, DAO structures, and fintech groups. Zug's Crypto Valley concentration provides ecosystem access. Capital denominable in USD or other currencies since 2023.
Family office structure
AG as the holding vehicle for family wealth, providing shareholder privacy (no public register), centralised governance via board, and efficient dividend routing across jurisdictions. Participations in real estate, funds, and operating companies held under one roof.
IP holding company
Swiss AG holding patents, trademarks, or proprietary software. Royalty income subject to patent box (StHG Art. 24a, up to 90% cantonal reduction). Combined with participation exemption on downstream dividends from operating subsidiaries.
Post-STAF (2020): the holding privilege is abolished
Before the 2020 STAF reform, Swiss cantonal law granted holding companies a special "Holdingprivileg" — a 0% cantonal tax rate on qualifying holding income. This privilege was abolished on 1 January 2020 as part of Switzerland's OECD-compliant reform. All Swiss holding companies are now taxed at the general cantonal rate. In Zug, that rate is 11.85% combined — still the lowest in Switzerland and competitive with any European jurisdiction for holding structures. See our Swiss corporate tax guide for full cantonal rate comparisons.
Formation Process
How to establish a Swiss holding company.
Step by step.
Structure Design
Assess the group structure: number of subsidiaries, jurisdictions, IP assets, and beneficial owner profile. Determine whether an intermediate or top-level holding is optimal, and whether a Zug AG or another canton better serves the purpose. Goldblum & Partner prepares a written structure memorandum.
Swiss AG Incorporation
Articles of association drafted, capital deposit account opened at a Swiss bank (CHF 100,000 minimum, CHF 50,000 paid-in). Notary appointment in Zug via power of attorney — no travel required. ZEFIX commercial register publication within 14 days.
Substance & Governance Setup
Swiss-resident nominee director appointed (OR Art. 718(4)). Board meeting calendar established in Zug. Baarerstrasse 25 registered address activated. Minute books and share register prepared. Swiss entity bank account opened for dividend flows.
Ongoing Compliance
Annual accounts under Swiss GAAP (OR Art. 958). Corporate tax return filed with Zug Steuerverwaltung. Participation exemption (DBG Art. 69) applied to qualifying dividend income. Patent box (StHG Art. 24a) filed if IP income arises. Goldblum & Partner handles all compliance.
Jurisdiction Comparison
Why Switzerland for a holding company.
Zug vs. Luxembourg, Netherlands, Cayman.
Criterion
Zug (CH)
Luxembourg
Netherlands
Cayman
Non-EU status is a feature, not a bug.
Switzerland is not bound by EU state aid rules, EU tax directives, or ATAD restrictions. The bilateral approach gives Swiss holding structures more flexibility on dividend flows than intra-EU structures. Holding vehicles are typically formed as a Swiss AG — see our full Swiss company formation guide for the incorporation process.
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.
Free consultationRelated Services
Official Sources
- DBG Art. 69–70 — Participation Exemption
Federal law — tax relief on dividends from qualifying participations
- StHG Art. 28 — Holding Company Privilege
Cantonal tax harmonisation — holding company tax treatment
- ZEFIX — Company Search
Federal commercial register — verify registered Swiss holdings
- ESTV — Withholding Tax (Verrechnungssteuer)
35% WHT on Swiss-source dividends — refund procedures
- SECO — Investment in Switzerland
Swiss Economic Affairs — investment location information
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Baarerstrasse 25 · 6300 Zug · Switzerland · Est. 2007