Europe · GmbH
Switzerland company taxes
Switzerland taxes corporate profit in three layers — federal, cantonal and communal — and the canton you pick is the single biggest lever on your bill. The federal direct tax is a flat 8.5% on profit after tax (about 7.83% on a pre-tax basis), and on top of that every canton and its communes add their own rate. The EFFECTIVE COMBINED rate therefore swings widely: roughly 11.85% in Zug and ~12.15% in Lucerne at the low end, up to ~19.6% in Zurich and ~20.5% in Bern. That spread is legal and intentional — locating a GmbH in a low-tax canton is a core part of why Switzerland is attractive. For a foreign owner, the headline trap is the opposite of the UK's clean exit: Switzerland levies a 35% federal withholding tax (Verrechnungssteuer) on dividends at source. Your GmbH must withhold 35% of any distribution, and you — the non-resident shareholder — then reclaim the excess over your treaty rate from the Swiss authorities. So while the corporate rate can be very low, getting the after-tax cash to yourself involves a withholding-and-refund cycle that you must plan for. There is also a small annual cantonal/communal capital tax on equity, and VAT at 8.1% once you cross CHF 100,000 of turnover.
- Country
- Switzerland
- Topic
- Taxes
- Reviewed
- June 2026
By the Lanzamo Editorial Team · Reviewed June 2026 · How we research
| Tax | Rate | Notes |
|---|---|---|
| Corporate tax — federal direct tax | 8.5% | Flat federal rate on profit after tax (~7.83% effective pre-tax); the same nationwide. |
| Corporate tax — effective combined | ~11.8%–21% | Federal + cantonal + communal. E.g. Zug ~11.85%, Lucerne ~12.15%, Zurich ~19.6%, Bern ~20.54% — driven by canton choice. |
| VAT — standard rate | 8.1% | Reduced 2.6% (food, books, medicine) and special 3.8% (accommodation). Registration mandatory above CHF 100,000 worldwide turnover. |
| Withholding tax — dividends | 35% | Federal Verrechnungssteuer withheld at source on distributions; non-residents reclaim the amount above their treaty rate. |
| Withholding tax — interest / royalties | 0–35% | No general WHT on ordinary royalties; certain interest (e.g. bonds, bank interest) is subject to 35% WHT, reduced by treaty. |
| Capital tax (annual) | varies | Small annual cantonal/communal tax on net equity; rate and any minimum depend on the canton. |
| Issuance stamp duty on capital | 1% | 1% on equity contributions above a CHF 1,000,000 exemption — so a standard CHF 20,000 GmbH pays nothing. |
Corporate tax: the three layers and why canton choice dominates
Profit is taxed federally at a flat 8.5% (about 7.83% effective because the tax is deductible against itself), then again by the canton and the commune where the company has its seat. Because cantons set their own rates, the effective combined burden ranges from roughly 11.85% in Zug to about 20.5% in Bern, with Zurich near 19.6% and Lucerne near 12.15%. For a non-resident, this means the where decision is a tax decision: the same GmbH can pay nearly double the tax across the Roesti border. Pick the canton with eyes open, and remember the communal layer can shift the headline figure by a point or so within a canton.
VAT and the worldwide-turnover threshold
Swiss VAT is 8.1% standard (with 2.6% reduced and 3.8% special rates), notably lower than the EU. Registration becomes mandatory once worldwide turnover from taxable supplies reaches CHF 100,000 — and crucially the test counts your global turnover, not just Swiss sales, so a busy foreign-controlled company can be pulled in even with modest Swiss revenue. A liable company without a fixed Swiss establishment generally must appoint a Swiss fiscal representative for VAT. Below the threshold, voluntary registration is allowed if you want to recover input VAT. Returns are filed quarterly, with payment due within 60 days of each quarter's end.
Dividends and the 35% withholding tax for foreign owners
This is where Switzerland diverges sharply from the UK. Every dividend a GmbH pays is subject to a 35% federal withholding tax (Verrechnungssteuer) deducted at source. A non-resident shareholder then files to reclaim the difference between 35% and the rate allowed under the double-tax treaty between Switzerland and their country of residence (residual treaty rates are commonly 15%, dropping to 5% or even 0% for qualifying corporate shareholders with a substantial holding). The cash-flow effect is real: you receive 65% up front and recover the rest later, so model the timing and confirm your treaty position before you distribute.
How a non-resident-owned company is taxed
A GmbH is Swiss tax-resident because it is incorporated and seated in Switzerland, so Swiss corporate tax applies to its profits regardless of where you live. Your personal non-residence does not move the company's tax base offshore. What you do control is the canton (and therefore the rate), and how you extract profit — salary to a Swiss-resident managing officer is deductible at the company level but triggers Swiss social security, while dividends face the 35% withholding-and-reclaim cycle. The participation exemption can substantially relieve tax on qualifying dividend income the GmbH itself receives (broadly holdings of at least 10% or worth CHF 1,000,000), which matters mainly for holding structures.
Losses, the capital tax and incentives
Tax losses can be carried forward for seven years to offset future profits (an extension toward ten years has been moving through the federal legislative process — confirm the rule in force for your period). Switzerland also levies a small annual cantonal/communal capital tax on the company's net equity, which some cantons let you credit against income tax. The 1% issuance stamp duty on capital contributions only bites above a CHF 1,000,000 exemption, so a normal CHF 20,000 GmbH pays none. Note the OECD/Pillar Two 15% minimum top-up tax now in force in Switzerland applies only to large multinational groups with consolidated revenue of at least EUR 750 million — ordinary start-ups are unaffected and keep their low cantonal rate.
Filing calendar
The corporate tax return is filed annually with the cantonal tax office; deadlines vary by canton but are typically six to nine months after the financial year-end, with extensions commonly available. Statutory financial statements must be prepared each year (audit only if you exceed the small-company opt-out thresholds). VAT returns, once registered, are generally quarterly with payment due within 60 days of the quarter end. Cantonal practice differs on provisional invoicing and instalments, so the fiduciary handling your books will manage the exact dates for your canton.
Frequently asked questions
What is the lowest realistic corporate tax rate for a Swiss GmbH?
Around 11.85% effective combined in the canton of Zug, with Lucerne close behind near 12.15%. That includes the flat 8.5% federal layer plus the canton's and commune's own rates. Higher-tax cantons like Bern (~20.5%) or Zurich (~19.6%) roughly double the bill, which is why choosing the canton is effectively choosing your tax rate.
Will Switzerland withhold tax when my GmbH pays me a dividend abroad?
Yes — and heavily. There is a 35% federal withholding tax (Verrechnungssteuer) on every dividend, deducted at source. As a non-resident you reclaim the portion above your treaty rate (often reduced to 15%, or 5%/0% for qualifying corporate shareholders) by filing with the Swiss tax authority. You effectively get 65% immediately and recover the rest, so plan the cash-flow and timing.
Does the OECD 15% minimum tax apply to my Swiss start-up?
Almost certainly not. Switzerland's Pillar Two top-up tax (a domestic minimum top-up plus an income-inclusion rule) applies only to multinational groups with consolidated annual revenue of at least EUR 750 million. An ordinary owner-managed GmbH is far below that, so nothing changes — you keep your canton's low effective rate.
Do I have to register for VAT as a non-resident with few Swiss sales?
Possibly — because the CHF 100,000 threshold is measured on worldwide taxable turnover, not only Swiss-source revenue. A company with high global turnover but modest Swiss sales can still be required to register, and a liable foreign-controlled company without a fixed Swiss establishment generally needs a Swiss fiscal representative. Below the threshold you can register voluntarily to recover input VAT.
Sources
- Zefix — Federal Central Business Names Index / commercial register (official)
- ESTV / FTA — Swiss Federal Tax Administration (official)
- ESTV / FTA — Swiss VAT rates (official, 8.1% standard)
- ESTV / FTA — Withholding tax (Verrechnungssteuer, official)
- EFD / Federal Department of Finance — Implementation of the OECD minimum tax in Switzerland
- Swiss Code of Obligations — Art. 814 (managing officers, Swiss-resident representative)
- PwC Tax Summaries — Switzerland corporate taxes on income
- PwC Tax Summaries — Switzerland other taxes (issuance stamp duty, capital tax)
- PwC Switzerland — international corporate tax comparison (cantonal rates)
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