July 2025
For Swiss businesses operating across borders, effective international tax planning has become increasingly complex yet critically important. As global tax regulations evolve and tax authorities enhance their cooperation, companies need sophisticated strategies that balance compliance with optimization.
When developing your international tax strategy, focus on these critical elements:
Substance and Business Purpose: Ensure that your international structures reflect genuine business activities and economic substance rather than being driven solely by tax considerations.
Transfer Pricing Alignment: Develop robust transfer pricing policies that align with your business operations and can withstand scrutiny from multiple tax authorities.
Treaty Network Optimization: Leverage Switzerland's extensive tax treaty network to minimize double taxation while ensuring compliance with anti-abuse provisions.
Permanent Establishment Management: Carefully manage activities that could create taxable presence in foreign jurisdictions, particularly in the context of remote working and digital business models.
Several significant developments are reshaping international tax planning:
OECD Two-Pillar Solution: The global minimum tax and new profit allocation rules are fundamentally changing how multinational enterprises are taxed.
Enhanced Transparency: Automatic exchange of information, country-by-country reporting, and beneficial ownership registers have dramatically increased tax transparency.
Digital Economy Taxation: New approaches to taxing digital services and online activities are emerging globally, creating both challenges and opportunities.
Switzerland offers distinctive advantages for international tax planning:
Competitive Tax Rates: Despite global tax reforms, Switzerland maintains relatively attractive tax rates and special tax regimes for certain activities.
Extensive Treaty Network: Switzerland's comprehensive tax treaty network helps prevent double taxation and provides certainty for cross-border operations.
Stability and Predictability: The Swiss tax system offers a high degree of legal certainty and administrative cooperation.
At SSDG, we help clients develop international tax strategies that are:
Compliant and Sustainable: Designed to withstand increased scrutiny and evolving regulations.
Business-Aligned: Integrated with your operational strategy rather than driving business decisions.
Forward-Looking: Anticipating future developments in the global tax landscape.
By taking a strategic, compliance-focused approach to international tax planning, Swiss businesses can navigate complexity, manage risks, and optimize their global tax position. Our tax advisors combine deep technical expertise with practical business experience to help clients develop effective international tax strategies.
Need help optimizing your international tax position? Our tax experts can help you develop a strategy that balances compliance with efficiency.
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