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The
Swiss Stock Corporation
(Société Anonyme or Aktiengesellschaft)
Switzerland
is a low-tax jurisdcition having a series of specialized corporate
forms which can be used by non-resident individuals and international
companies to reduce their tax bill to a significant extent.
The most
interesting corporate form is the Swiss stock corporation ("Société
Anonyme" or "Aktiengesellschaft"), which can avail
itself of the numerous double taxation treaties signed by Switzerland,
representing thus an interesting vehicle in the planning of international
trading or assets protection structures.
There
are five main variants of the Swiss Stock Corporation:
Domiciliary
company : domiciliary stock corporations are companies that
have a registered office in Switzerland but are foreign-controlled,
carry out all of their business abroad, have no staff in Switzerland
and receive only foreign source income; the use of this type of
companies can result in savings on both income tax and capital gain
tax as well as net worth tax.
Holding
company : a holding company is a stock corporation with
a particular tax status, benefitting from reductions in income tax,
on capital gain at federal and cantonal levels, and on net worth
tax; a company limited by shares is defined as a holding company
if it holds at least 20% of the share capital of another company
or if the value of its shareholding in another company has a value
of at least 2 millions Swiss Francs.
Service
company : the activity of this type of company is the provision
of technical, management, marketing, financial and administrative
services to foreign companies which belong to the same group of
which the limited company is a member; this type of limited company
can avail itself of interesting tax deductions by means of an advance
tax ruling.
Auxiliary
company : it is basically a domiciliary company which carry
out a certain part of its business in Switzerland; tax reductions
varies depending on the canton, but auxiliaries companies may have
Swiss offices and personnel and generate Swiss income, though the
major part of the income must be of foreign source.
Mixed
company : a mixed company has at the same time the characteristics
of a domiciliary company and of a holding company; the use of this
type of company may result in tax savings at cantonal and communal
levels if it is foreign controlled, if at lest 80% of its total
revenue comes from foreign sources.
Characteristics of a Swiss stock corporation:
Minimum
share capital: CHF 100'000.- ;
Minimum
number of subscribers: 3 ;
Bearer
shares: permitted ;
Nominee
shareholders : permitted ;
Minimum
number of directors: 1 ;
Fiduciary
directors: permitted ;
Company
must have an auditor.
Loralie
sa
Trustee
& Financial Services
Place Saint-François 12 bis - 1003 Lausanne
(Suisse)
Téléphone : +41-21-643.10.20 - Télécopie
: +41-21-643.10.21

info@loralie-group.com
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