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| 1. THE WAY TO GO |
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| Over the last few
years, the economy of the four cantons has progressed
from |
- the mechanical industry to high technology
and microtechnology,
- food to pharmaceuticals, biotechnology and
cosmetics, and
- watches to other luxury products and other
precision instruments.
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| Western Switzerland
has become a recognized leader in |
- microtechnology, including electronics hardware
and software, telecommunication, special machinery
such as robots, and medical devices
- the life sciences sector and luxury products,
and
- international management, finance and trade.
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Our knowledgeable workforce,
excellent infrastructure, and stimulating business environment
are tailor-made for cutting edge technologies. The cantonal
governments are committed to using their resources to
the utmost in attracting and retaining international
economic development.
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1
TAXATION
Western Switzerland
offers you a comprehensive, flexible program for new
activities. All tax alleviations and exemptions are
subject to a tax ruling by the tax authorities of the
state or canton where the project will be realized.
| A. INDUSTRIAL
AND SERVICE INDUSTRY COMPANIES |
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A newly created
company, industrial or service industry company
qualifies for
State,
municipal and federal tax alleviations on
profit and capital
Maximum : 100 percent exemption of taxable
profit and of taxable capital
Maximum duration of 10 years |
The decision depends
on the approval of the company's business plan
by the bank, the state, and the federal government,
respectively. These entities primarily take into
consideration the contribution of the project
to the area and the quality of the management,
the company and the activities.
The federal
tax alleviations mainly apply to industrial areas
of Western Switzerland and exclude certain regions
on Lake Geneva.
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| B. COMPANIES
WITH INTERNATIONAL ACTIVITIES (MIXED COMPANY) |
| |
International
services companies that are controlled from abroad
and have at least 70 percent of their revenues
coming from abroad qualify for a privileged tax
rate *.
Maximum
between 10 to 11 percent taxation of profits
resulting from foreign revenues (federal,
state and municipal)
Taxation of capital between 0.1 and 0.16 percent |
| This rate
applies chiefly to revenue coming from: |
- Distribution of goods
- International commercial activity (purchase
and sale of any products that do not pass
through Switzerland)
- Account management (financing, cash
management, currency)
- Licences, diplomas, trademarks, and
patents
- Operations of European or international
headquarters (accounting, salaries, information
collection, etc.)
- Centralized purchases
- Leasing
- Income from any company-related insurance
program
- Marketing
|
Please note
:
In Switzerland, company taxes paid are considered
as deductible commercial expenses. What matters
is the effective net tax rate which already takes
into consideration the above deduction possibility.
This documentation therefore indicates the effective
net tax rates.
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| C. DOMICILIARY
COMPANY |
| |
International
services companies that focus exclusively on administrative
activities, are not engaged in any commercial activities
and have practically no Swiss revenue (less than
5 percent) qualify for a privileged tax rate.
Maximum
between 9 and 11 percent taxation of profits
resulting from foreign and Swiss revenues
(federal, state and municipal)
Taxation of capital between 0.1 and 0.16 percent |
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| D. PRINCIPAL
COMPANY |
| |
Swiss companies
often are part of an international group and sell
their goods through foreign commissionaires who
are part of the same group. The Swiss authorities
may consider such commissionaires as permanent establishments
of the Swiss Company acting as the principal. The
tax authorities can reduce the taxable profit realized
by the Swiss principal to 50 percent, cutting the
overall tax burden to a level between 6 and 8.5
percent. |
| E. SERVICE
COMPANIES (COST PLUS) |
| |
Administrative
companies perform functions or services for foreign-affiliated
firms, offering administrative, technical, scientific,
or marketing assistance. Such costs are covered
by an affiliated company that in numerous cases
is the parent company. Administrative companies
are taxed according to the system of cost plus.
The tax burden is between 1 and 2 percent of the
local direct expenses principally salaries and rent.
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| F. HOLDING |
| |
Dividends coming
from substantial participation
are exempt from taxes at the state, municipal and
federal levels, for an unlimited amount of time.
If the participation is not substantial (i.e., interest
is less than 20 percent of the firm's capital or
less than two million Swiss francs), dividends are
subject to normal tax income.
The capital tax is between 0.1 and 0.16 percent.
|
2 FINANCIAL ASSISTANCE
A newly created
venture from the industry or service industry can benefit
from the following advantages:
A - State guaranteed loan
| Total
amount : |
maximum 1/3 of
total project cost
(minimum investment : CHF 900,000) |
| Duration
: |
maximum 8 years,
fixed amortization |
B - Contribution to interest
service
| Total
amount : |
maximum 50 percent
of interest on a total amount, secured or not, representing
a maximum of 1/3 of the total project cost
(maximum principal : CHF 5 million) |
| Duration
: |
maximum 6 years,
fixed amortization |
The principal criteria
taken into consideration for the state guaranteed
loan and the interest services are the contribution
of the project to the area, the quality of the management,
the company and the activities.
The financial program focuses mainly on the industrial
areas and cover most regions of Western Switzerland.
C - Financing studies
Western Switzerland
can help underwrite the cost of studies whose objective
is to introduce new projects and will improve product
development, production, or the general organization
of a company in the area.
| Total
amount : |
50 percent of the
agreed-upon costs of the study, maximum CHF 30,000 |
In order
to receive this subsidy, companies must meet
the following criteria : |
- retain an external consultant
- integrate the project results with
the company's global strategy
- present the request before beginning
the study
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3 TRAINING ALLOWANCES
A - Job contributions
Companies bringing
new activities that require the training of an entire
group of employees may obtain a cash grant up to CHF
10,000 for each new job created.
B - Technical Training
Allowances (for local workers)
This allowance is
designed to encourage the recruitment of local workers
by partially financing the salary of employees who
need to improve their job skills.
Qualified employees
are those who need specific training to adapt their
skills to a new position. This applies to Swiss employees
as well as to those who already possess a B or C work
permit. Expatriates recruited by the company are not
eligible.
Advantages
A maximum of 40 percent of gross salary for a period
of six months, for a maximum contribution of CHF
10,000 to 15,000 per employee granted to help cover
the costs of a training program |
C - Unemployment Insurance
Allowance Law
This allowance encourages
companies to hire the unemployed, who have difficulty
reintegrating into the work force.
The allowance applies only to those people who are
registered in a job-seeking position under a Swiss
jurisdiction.
Advantages
Up to 40 percent of gross salary calculated for
a maximum period of six months. Maximum contribution
of CHF 20,000 per employee granted to help cover
the costs of a training program |
4 RESEARCH AND DEVELOPMENT
GRANTS
The Confederation
supports applied research and development projects through
special funds. Companies can benefit from the federal
aid by executing the project through co-operation with
a Swiss University or independent research Institute.
The support may reach up to 50% of the project cost.
The federal money is destined to cover the cost of the
university or of the institute. As a result the company
has not to pay for the contribution of the universities
or the institutes to the project.
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| 3.
WORK AND RESIDENCY PERMITS |
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In Switzerland,
different types of work and residency permits exist.
They are described below (appendix 8).
We will assist in obtaining work and residency permits
for all managers, specialists and foreign owners who
are essential to the success of the project and not
otherwise available in the Swiss job market, thus enabling
them to live and work with their families in Switzerland.
Basically, there is now a difference between EU/EFTA
members and third countries.
The allotment to EU/EFTA members has been widely enlarged
in a Federal quota.
The State Quota
The Federal government
annually determines how many work permits each state
receives. Permits are divided into three distinct categories:
establishment permit, short time and border.
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| 1. General |
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Switzerland has
a federal structure consisting of municipality,
canton and the Confederation. Each of the 3 units
levies direct taxes. However, the company and the
individual tax payer deal with one single tax administration
representing all 3 levels, usually the Canton or
the municipality.
The tax system is the same for the whole of Switzerland.
However, as the different cantons and municipalities
can determine the tax load, we may face certain
differences.
The municipalities, the cantons and the Confederation
tax the profit of the companies and the income of
individuals. However, only the municipalities and
the cantons levy a capital tax for companies and
a wealth tax (assets) for individuals.
In Switzerland, company taxes paid are considered
as deductible commercial expenses. What matters
is the effective net tax rate which already takes
into consideration the above deduction possibility.
This documentation therefore indicates the effective
net tax rates.
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| 2. Companies |
| |
Holdings,
domiciliary and mixed companies do not only
benefit from alleviations for the income tax
but also pay the following special capital
tax rates |
0.1
to 0.16% |
New attractive industrial activities are eligible
for alleviations.
The following summary (see next page) gives a
general view on company taxation.
TAX
COMPARISON CHART
(with and without tax reductions) |
FEDERAL,
STATE, MUNICIPAL |
| ACTIVITY |
EXEMPTIONS |
MAXIMUM
DURATION |
EFFECTIVE
TAX RATE PERCENT |
Industry/Services
linked to industry |
municipal,
state, and federal exemptions |
5
- 10 years |
- |
Industry/Services
linked to industry |
municipal
and state exemptions |
5
- 10 years |
7.83 |
International
Services
Company(Mixed company) |
municipal
and stateforeign income |
unlimited |
10
- 11 |
| Domiciliary
company |
municipal
and stateforeign income |
unlimited |
9
- 11 |
Commissionaire
structure
(principal) |
municipal,
state and federal 50% of taxable profit |
unlimited |
6 - 8.5 |
| Service
company |
Cost
plus 5 percent |
unlimited |
1
- 2 |
| Holding |
Municipal,
state and federalsubstantial dividends |
unlimited |
- |
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| Industry |
normal
taxation |
- |
22
- 23 |
| Services |
normal
taxation |
- |
22
- 23 |
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Note
The "Effective
Tax Rate" is what remains after the deduction
of taxes. (Company Taxes are deductible in Switzerland).
This method of calculating is specific to Switzerland.
It applies to all forms of income taxes, with
the exception of administrative companies that
do not actually generate profits.
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| 3. Individual
taxes |
| |
The tax rates
are progressive. The taxes are to be paid on the
taxable net income, i.e. gross income in general
minus all social security payments and also minus
interest payments.
For foreign managers, special deductions can additionally
be made. See next page.
The income tax load on a professional net income
between CHF 150,000 and 250,000 amounts to about
25% at all 3 levels together.
| COMPUTATION
BASED ON UNCEILED 2ND PILLAR CONTRIBUTION |
| Gross salary |
233'645 |
|
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| + Representation
fees |
16'355 |
Assumption |
7% of gross
salary |
| Total
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250'000 |
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Social Security
contributions
(employee's part) |
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| ·
AVS/AI/APG |
-
11'799 |
Old
age, infirmity, disability |
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AC |
-
2'870 |
Unemployment |
| ·
LAA |
-
1'160 |
Non-professional
accident |
| ·
2nd pillar |
-14'019 |
Option
among others : contribution of 6% |
| Total
of Social Security contribution (employee)
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29'848 |
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12.8% of
gross salary |
| Gross taxable
revenue |
203'797 |
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| Family allowances
(min.) |
300 |
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| Taxable base |
204'097 |
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| Minim. deduction
linked to cantonal legislation |
-
11'121 |
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| Expatriates
deduction |
-
18'000 |
Minimum |
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| Buy-back
of missing years in 2nd pillar |
0 |
Per year |
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| Net taxable
revenue |
174'976 |
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Canton &
Commune taxes
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29'575 |
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| Federal
taxes
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-
10'847 |
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| Total of
taxes |
-
40'422 |
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17.3% of
gross salary |
| Net salary
after social contributions and taxes |
163'675 |
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70.1% of
gross salary |
| + Representation
fees |
16'355 |
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| Total |
180'030 |
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72% of the
global remuneration |
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| 6.
SUMMARY OF PERMIT TYPES EU AND EFTA |
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| DURATION |
TYPE |
DESCRIPTION |
| State
permits |
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| Establishment
permit 5 years |
Permit
B EU /EFTA |
For
new workers who need to reside in the state.
Family regrouping and geographic & professional
mobility allowed. Independent activity must
get a specific authorization. Limited allotment |
| Establishment
permit 5 years |
Permit
B EU /EFTA |
For
workers who can justify a 30 months working
period in Switzerland Family regrouping and
geographic & professional mobility allowed.
Independent activity must get a specific authorization.
No allotment |
| Short
time permit less than 12 months |
Permit
L EU /EFTA |
For
activities performed during 364 days maximum
As long as the contract's duration. Can be
renewed without quitting the territory. Family
regrouping and geographic & professional
mobility allowed. Limited allotment |
| Short
time permit less than 4 months |
Permit
L EU /EFTA |
Short
time mandate. Family regrouping and geographic
& professional mobility allowed. No allotment. |
| Short
time permit, max. 90 days per civil year |
Permit
L EU /EFTA |
For
service provider as an independent or as a
company. Allows job searching, medical treatment
or cure. Family regrouping and geographic
& professional mobility allowed. No allotment. |
| Border
5 years permit |
Permit
G EU /EFTA |
For
workers who are living in a border zone. Possibility
to acquire a second home on the whole Swiss
territory. Weekly home return compulsory.
Free ability to work and live in the whole
Swiss territory. No allotment. |
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| 7.
SUMMARY OF PERMIT TYPES FOR THIRD COUNTRIES (OUT OF EU/EFTA) |
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| DURATION |
TYPE |
DESCRIPTION |
| State
permits |
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| Yearly |
Permit
B |
For
workers who need to reside in the state. Renewable
annually. Family regrouping allowed. Geographic
& professional mobility under specific
authorizations. Limited allotment. |
| 12
months maximum |
Permit
L |
For
specific mandate for business. As long as
the contract's duration. Limited allotment. |
|
4 months maximum |
Permit
L |
For
specific mandate for business. As long as
the contract's duration. Family regrouping
and geographic & professional mobility
not allowed. Limited allotment. |
| 120
days discontinuous |
Permit
L |
For
specific mandate for business. Family regrouping
and geographic & professional mobility
not allowed. No allotment. |
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