Structure
Holding company
Incorporate the Swiss holding or group company with the right share and governance setup.
Holding companyInternational Holdings & MNE
in Switzerland.
A Swiss holding company is only as good as the substance behind it. Since the global minimum-tax rules landed, a letterbox holding is a liability, not a shield. We build holding and group structures with genuine substance (people, premises, decisions taken in Switzerland) that hold up to a tax authority and a Pillar Two review.
At a glance
Substance and entity management are core; tax planning runs alongside them.
Independent since 2007 · IFLR1000-ranked · offices in Zurich and Zug · one partner per file.
- Build
- Substance, not letterbox
- Pillar Two
- 15% minimum-tax planning
- Structures
- Holdings, IP, finance, SPVs
- Test
- Survives authority review
The challenge
What this sector has to get right in Switzerland
Multinationals use Switzerland for holding, financing and IP because the legal system is stable and the tax position is competitive. But the bar for what counts as a real establishment has risen. A holding company that exists only on paper (no local directors with authority, no premises, no decisions actually taken in the canton) is exposed on permanent-establishment, place-of-management and beneficial-ownership grounds, and increasingly on substance tests written into treaties and domestic law.
The OECD global minimum tax sharpens this. For groups in scope, a 15% effective floor applies regardless of headline rate, and the substance-based carve-out is calculated from real payroll and tangible assets in the jurisdiction. That changes the planning question from 'where is the rate lowest' to 'where does real activity sit and how is it evidenced'. A Swiss holding now has to be designed with both the legal substance and the Pillar Two arithmetic in mind from the start.
We assemble the structure and the substance together: the holding or finance entity, resident directors who genuinely act, registered premises, and entity management that documents the decision-making. Tax structuring sits on top of that base rather than substituting for it.
What this desk handles
The services this sector uses most
Each links to the service page itself. Most mandates here combine several; one partner co-ordinates them.
Substance
Swiss substance package
Premises, resident directors and documented local decision-making that evidence a real establishment.
Swiss substance packageMinimum tax
Pillar Two advisory
Model the 15% floor, the substance carve-out and the top-up exposure for groups in scope.
Pillar Two advisoryTax
International tax structuring
Treaty access, withholding and group financing planned around the substance you actually have.
International tax structuringVehicles
SPV administration
Run the financing and sub-holding vehicles the group uses, with their own substance.
SPV administrationGovernance
Directorship services
Resident directors who genuinely exercise authority, not nominees on a register.
Directorship servicesOngoing
Entity management
Keep the whole group's registers, filings and board records current and consistent.
Entity management
Talk to the desk
Speak to a partner who knows the sector
No intake form to a junior, no call centre. The partner who reads your enquiry is the one who has run this structure before, and the one who will own your file. Outline your situation and you will have a considered reply, with the likely route and the next step, within one business day.
Why Goldblum and Partners
Swiss depth, one accountable partner
Substance is now where holding structures are won or lost. We build the legal substance and plan the Pillar Two position on one desk, have been independent since 2007, and have been ranked by IFLR1000 every year from 2015 to 2026. The directors we provide actually act; the premises are real; the decisions are documented, which is what a tax authority looks for.
Placing a holding or group structure in Switzerland?
Tell us your group, where value is created and whether Pillar Two applies. A partner will design a structure with substance that holds — and reply within one business day.