The Swiss prestigious option: is there confidentiality

1. The Swiss prestigious option: is there confidentiality Globalserve Seminar November 2013 ByPhani Schiza Antoniou

2. Why Switzerland • One of the major and reputable international Business centers • Tax regime • Extensive Network of double Tax Treaties; 90!! • Special relationship with EU , EU directives apply • Sound and prestigious Banking system • Confidentiality • High professional standards • Excellent infrastructure • Tax Rulings possible • Pro Business environment • High standard of living and quality of life • Multicultural and multilingual society

3. Types of swiss legal entities • There are two types of corporation at the forefront of commercial activity in Switzerland: “Corporation (SA/AG)” and “Limited Liability Company (Sàrl/GmbH)”. • These two kinds of legal entity offer the following main benefits: • Liability and risk limited to capital • Simple transferability of participation rights/shares • Regulated representation rights • AG is more prestigious, minimum capital CHF 100000 and confidentiality for shareholders • GMBH min CHF 20000 and transfer of shares is registered • Comparable with foreign legal entities such as the German GmbH, the US “Joint Stock Company”, the English “Limited Liability Company” and the French “SociétéAnonyme”. • Besides forming a Corporation “AG” / “SA” or a “GmbH”/GmbH, it is also mainly possible to have a branch of a foreign corporation inscribed in the Commercial Register, or to establish a private company which is not a legal entity in its own right.

4. Summary ofSwissTaxRates

5. Company Structures (Special tax status)

6. Company Structures (Special tax status) 2010 KPMG: International corporate tax. Investment in Switzerland

7. Swiss Trading Branch of foreign low tax legal entity • Possibility of avoiding 35% Swiss WHT if there is not a center of business decisions in Switzerland. • Possibility of getting favorable tax rate according to special tax ruling to be achieved. Ex.: 6.5% in Ticino, 5% in Zug. US LLC or Cyprus Ltd. Swiss Branch Invoice EUR/CHF Invoice EUR/CHF Seller (non Swiss based) Buyer (non Swiss based) Payment EUR/CHF Payment EUR/CHF Goods

8. Principal companies are companies which centralize the functions and risks of an international group and do business through contract manufacturing and limited risk distributor agreements: Reduced effective income tax, depending on the international income allocation up to 5-7% (depending on canton) Taxation of Principal companies in Switzerland Foreign Parent (Un) related Manufacturers Swiss Principal Commissionaire entities Limited risk distributors Contracts Goods Client 2010 KPMG: International corporate tax. Investment in Switzerland

9. Foreigners are limited in buying residential real estate in Switzerland: Secondary housing is not welcome in Switzerland… Therefore the possibility to take residence under the lump sum taxation allows foreigners to buy residential real estate without any limits. Low tax regime which allows acquisition of Swiss residential real state

10. DOUBLE TAX TREATY WITH UKRAINE

11. DOUBLE TAX TREATY WITH RUSSIA

12. Comparison Luxembourg, Dutch & Swiss TaxRates

13. Comparison of Luxembourg, Dutch & SwissTaxRates • .

14. Comparison of Luxembourg, Dutch & SwissTaxRates • .

15. Comparison of Luxembourg, Dutch & SwissTaxRates • .