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Switzerland Fact-File Part 2:
Individual Business Domestic Taxation

2.6 Switzerland Partnership Income Taxation

The Tax Treatment of General and Limited Partnerships

Partnerships in Switzerland may be treated as an entity or as a business run by individual partners and may be general or limited partnerships. The essential difference is in apportioning income and tax liability. In the so-called ‘entity model’, the partnership is treated as a separate legal entity (Limited Partnership), whereas in the second option (known as the flow-through model) income, and therefore tax liability, is attributed to the partners (General Partnership). A partnership can also be a foreign partnership as this is permitted under Swiss law.

With a general partnership, income is attributed to each partner and is apportioned according to the investment in the partnership. Each partner is responsible for filing his or her own personal tax return and tax is paid at personal income tax rates. Partners are classed as self-employed and may deduct any losses, or proportion of partnership losses, before establishing their own taxable base.

In a limited partnership, the partnership is itself a separate legal entity and tax is paid at corporate income tax rates – partners are jointly and severally liable for tax and other debts of the partnership.

A partner may either be an individual or a company (corporation) and will be liable to pay tax at the appropriate rate (income tax or corporate tax).



 

Introductory Guides

Brief, clearly written summaries with links to relevant sections of the Fact-File. The Fact-File itself is linked in full below.

 

Fact-File

Part 1: Switzerland Business Formation for Individuals

  1. Switzerland Individual Business Structures
  2. Switzerland Individual Business Registration
  3. Switzerland Individual Business Registration Cost
  4. Switzerland Individual Business Licensing
  5. Switzerland Foreigners in Business
  6. Switzerland Business Organisations
  7. Switzerland Business Accounting
  8. Switzerland Family Business Ownership
  9. Switzerland Venture Capital
  10. Switzerland Individual Business Franchises

Part 2: Switzerland Individual Business Domestic Taxation

  1. Switzerland Individual Business Tax Residence Rules
  2. Switzerland Permanent Establishment
  3. Switzerland Individual Income Tax Rates and Bands
  4. Switzerland Personal Allowances and Business Deductions
  5. Switzerland Husband and Wife Partnerships
  6. Switzerland Partnership Income Taxation
  7. Switzerland Limited Companies Income Taxation
  8. Switzerland Business Profit Retention
  9. Switzerland Business Losses
  10. Switzerland Value Added Tax (VAT)
  11. Switzerland Individual Business Capital Gains Tax (CGT)
  12. Switzerland Individual Business Other Taxes
  13. Switzerland Individual Artists Royalties
  14. Switzerland Individual Business Tax-Efficient Profit Distribution

Part 3: Switzerland Individual Business International Taxation

  1. Switzerland Individual Business International Tax Liability
  2. Switzerland Individual Business Withholding Taxes
  3. Switzerland Double Tax Treaties

Part 4: Switzerland Individual Business Tax-Efficient Structures

  1. Switzerland Individual Business Tax-Efficient Structures
  2. Switzerland Individual Business Trusts and Foundations
  3. Switzerland Individual Business for Non-Residents
  4. Switzerland Individual Business use of Offshore
  5. Switzerland Controlled Foreign Corporation (CFC) Rules
  6. Switzerland Personal Estate and Inheritance Planning

Part 5: Switzerland Small Business Incentive Programs

  1. Switzerland Small Business Support Schemes
  2. Switzerland Training Incentive Schemes
  3. Switzerland R&D Tax Credits
  4. Switzerland Individual Business Tax Holidays

Part 6: Switzerland Individual Business Employment Issues

  1. Switzerland Individual Business Employer Responsibilities
  2. Switzerland Employment vs Self-Employment Tax Issues
  3. Switzerland Apprenticeship and Work Experience Schemes
  4. Switzerland Employee Dismissal Rules
  5. Switzerland Business Owner Employment and Invoicing Rules

Part 7: Switzerland Business Owner Welfare and Lifestyle

  1. Switzerland Business Social Security
  2. Switzerland Business Domestic Pensions
  3. Switzerland Offshore and International Pensions
  4. Switzerland Individual Business Healthcare
  5. Switzerland Individual Business Banking Services
  6. Switzerland Education
  7. Switzerland Individual or Business Leaving Switzerland
  8. Switzerland Domestic Real Estate
  9. Switzerland International Real Estate