International Tax Treaties & Planning
Switzerland's treaty network and optimizing your structure
Switzerland's Tax Treaty Network
Switzerland has signed over 100 double taxation agreements (DTAs), covering most major economies. These treaties determine how income is taxed when it crosses borders between Switzerland and the other treaty country.
Most Favorable Treaties
- Singapore: Dividend WHT reduced to 5% (with 10%+ ownership), interest 5%
- Netherlands: Dividend WHT 0–15% (holding structures)
- UK: Dividend WHT 0–15%
- Germany: Dividend WHT 5% (corporates with 10%+ stake)
- Hong Kong: Dividend WHT 10% (0% if 10%+ stake)
OECD BEPS Impact
The OECD BEPS (Base Erosion and Profit Shifting) project has introduced anti-avoidance rules including the "principal purpose test" — if the main reason for a structure is tax avoidance, treaty benefits can be denied. Structures must have genuine economic substance and business purpose.
Controlled Foreign Corporation (CFC) Rules
Many countries have CFC rules that attribute profits of foreign subsidiaries to domestic shareholders. Before setting up your Swiss structure, verify whether your country of residence has CFC rules and whether the Swiss company's income might be attributed to you personally.