True there are no CFC, but wouldn't they still consider an offshore company taxable in Switzerland if this controlled and owned by a swiss resident?
No CFC rules doesn't mean that you can operate an offshore company from CH.
True there are no CFC, but wouldn't they still consider an offshore company taxable in Switzerland if this controlled and owned by a swiss resident?
Right, PE would apply.No CFC rules doesn't mean that you can operate an offshore company from CH.