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Company in Switzerland, owner in the States - tax inversion ?

sriracha

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Aug 25, 2022
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I am seeing a ton of companies in the crypto space opening up in Zug, which has favorable taxation.

The setup is such that the company is incorporated in Zug, the owners are in US/EU, the employees are scattered around the world working remotely and the customers are from anywhere.

Problem is, the owners invariably reside and work from the US or EU, nobody obviously lives in Zug, which by the way seems to be so small as to not being able to physically contain these people.

Is it not tax inversion for the owners?
 
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It depends on how the company is structured, what tax treaties are applicable, and where exactly the owners and directors are based.

If the company has a director and one or two employees in Switzerland, that might be enough for the company to be considered Swiss under many tax treaties.

Switzerland isn't usually considered a corporate tax haven. It doesn't raise any flags for corporate tax evasion, the same way for example Seychelles and Belize do. Many tax authorities probably wouldn't question a structure involving a Swiss company and tax relief being claimed under a tax treaty.

The owners would of course have to pay tax (if applicable) on any dividends/income they receive from the company. But that's different from corporate tax residence.
 
What would be jurisdictions that would be problematic about that setup (director + employee)? I am imagining places with super aggressive tax offices like Greece.
There are literally millions of combinations of jurisdictions of company, holding company/companies, directors, employees, owners, and operations to be or take place in. We could sit here until the heat death of the universe going through them all.
 
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