Even if you don't pay any income tax on dividends?But it’s just the overall package that doesn’t make it very appealing
I don't believe you find anyone in Switzerland with knowledge about there system, tax and laws for CHF 1000 for such work.if you can recommend a - any - swiss service provider being active for your branch for chf 1,000... please post his name and address... have some dozen of clients interested in such an unique chance
The differences between the cantons should be quite small now.
I'll forward your message to Bloomberg's journalist. I'm sure she will be interested to know that.
That's definitely good, but it has more to do with Lichtenstein than with Switzerland, more details https://www2.deloitte.com/content/d...Tax/dttl-tax-liechtensteinhighlights-2020.pdf@marzio
I recently met a guy from Liechtenstein who told me of what is probably the best loophole with Switzerland:
If you live in Switzerland, but you register your company in Liechtenstein and you have an office in Liechtenstein (could even be in a co-working space) and there is no permanent establishment in Switzerland (=you don't work from Switzerland), then you only pay 12.5% corporate income tax in Liechtenstein and no tax on the dividends the company pays you.
This is due to special rules for the taxation of dividends that are set in the tax treaty between the two countries.
Obviously I guess that for this to be believable, you can't be living too far away from Liechtenstein and you should probably actually go to your office from time to time.
I think that owning a company in Liechtenstein (geez how difficult that name is?) will trigger CFC rules in Austria. In Switzerland there are no CFC rules so if you don't create a PE in Switzerland and do the work in Liechtenstein you're golden.
In case you commute regularly and have an office/substance in Liechtenstein, would that not be sufficient proof the company is not managed out of Austria?
Management is one thing, another thing is control. If you control 100% of a foreign company while being resident in Austria i guess it will trigger CFC rules in Austria.