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Domiciliary companies
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Domiciliary companies in Switzerland – what rights do they have?

Domiciliary companies are companies that only carry out administrative activities in Switzerland, but no business activity.

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What are domiciliary companies not allowed to do?

Pure domiciliary companies are not allowed to employ their own staff or maintain their own offices in Switzerland. The legal forms include stock corporations, limited partnerships, limited liability companies, cooperatives and more Business premises foreign corporations in question. There are no restrictions with regard to the purpose of the company.

Trading income from Switzerland is not permitted. The business activity must be carried out abroad, which means that purchases and sales should generally take place abroad (two-dimensional view). In exceptional cases, purchases can be made in Switzerland, provided that billing is guaranteed as with third parties. Domiciliary companies do not pay any cantonal or municipal taxes. You only pay the direct federal tax of 8.5% on the net profit.


In addition, the following are taxed at the regular rate:

  • Investment income (interest, dividends and capital gains) from Switzerland.
  • Income from intangible rights (licenses and trademarks) from Switzerland.
  • DTA-privileged income (interest and royalties) for which taxation in Switzerland is required.
  • Income from real estate in Switzerland.

The administration costs and taxes are usually deducted at a flat rate. The total winnings are decisive for determining the rate.

Tax-free income from abroad with domiciliary companies

For pure domiciliary companies, income from abroad is tax-free.

Net income from relevant investments (dividends and capital gains), taking into account investment losses (depreciation and provisions). Net losses from investments cannot be offset against domestic and/or foreign income.

The capital tax amounts to 0,075‰ of the taxable equity at the end of the tax period, but at least CHF 150,00, multiplied by the applicable tax rate of approximately 160% (in the canton of Zug). The equity consists of the paid-up share capital, share capital or share capital, the participation capital, the open reserves and hidden reserves formed from taxed profits as well as the balance sheet profit. At least the paid-in share capital, basic capital or share capital, including the paid-in participation capital, is taxable.

Jürgen Bächle
Jurgen Bachle

has been working as an independent tax consultant and expert in international tax law since 1989 and has been a member of the board of the German Association of Tax Consultants Baden-Württemberg, DSTVBW, for over 20 years.

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