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Taxation of mixed
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| The international mixed facilities serve as a hub for the activity of group of foreign companies and help to optimize taxation within the group. Their purposes may vary: - international commercial activity (purchase and sale of any products that do not pass through Switzerland) - account management (financing, cash management, currency) - licenses, trademarks and patents - leasing and marketing - operations of European or international headquarters (accounting, salaries, etc.) |
| Definitions |
| The term mixed company denotes a joint stock company, which has the characteristics of both domiciliary company and holding company, but which does not qualifies as either. Mixed company benefits from reductions in corporate income tax at cantonal and municipal levels or can be totally exempt, if it meets the following conditions: - it is both foreign-controlled and managed from abroad - it has a registered office, but has no staff in Switzerland - a minimum of 80% of its total income comes from abroad |
| Treatment of mixed companies for tax purposes |
| The use of mixed companies can result in savings in corporate income tax levied on income and capital gains. Most cantons grant mixed companies extensive tax privileges. Income (and capital) are taxed at a reduced rates. At a cantonal level a mixed company pays a tax between 0 to 11% of the regular corporate income tax. At a federal level there are no tax advantages in terms of corporate tax payable on income and gains (i.e. federal tax is determined by the rules applicable to ordinary companies valid throughout Switzerland – 8.5%). |
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