Switzerland Fact-File Part 2:
Individual Business Domestic Taxation
2.14 Switzerland Individual Business Tax-Efficient Profit
Distribution
Choosing Between Dividends, Salary and Fringe Benefits
Dividends are subject to a 35% withholding tax, whether paid
to residents or non-residents, including ‘hidden’
profit distributions (as defined under Swiss thin capitalization
rules).
Dividends paid from a Swiss subsidiary to its parent company
need only be reported and the dividends can be paid gross.
To qualify for this exemption, the parent company must have
a minimum 20% capital holding in the subsidiary. The exemption
applies only to cash dividends.
Given the relatively low personal income tax rates in Switzerland,
it would not appear to be financially attractive to make dividend
payments with any great frequency due to the high rate of
withholding tax.
The provision of so-called fringe benefits by companies
to their key employees is also a less attractive tax option
now. Benefits such as paying for travel, a company car, mobile
phone or membership of a sports club or gym might be ways
of providing benefits as opposed to a salary increase. However,
the tax authorities will examine such benefits closely to
determine whether they are genuine fringe benefits or should
be liable to tax.
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