Recommended seat
Switzerland
Current setup: 20 employees and 1 managing director in Austria | Current estimated cash-out: ~€115,887 / month
95.0 / 100
Executive Board Summary & Strategic Decision Matrix
Recommended seat
Switzerland
Current setup: 20 employees and 1 managing director in Austria | Current estimated cash-out: ~€115,887 / month
95.0 / 100
Status quo · Austria
~€1,850,647/yr
Payroll ~€1,390,647 + Tax €460,000 a year
Recommended seat · Switzerland
+~€405,932/yr
Total Company Cashflow Gain
Founder Personal Net Gain
Managing Director Personal Net Gain
+€25,802/yr
Maximum One-Off Over 3 Years
~€1,217,796total
Max one-off setup budget to break even within 3 yrs
Decision table · recommended seat and the next two options
| Legal home | Effective tax rate | Annual company cash effect | Time-to-payback / investment cap |
|---|---|---|---|
| SwitzerlandRecommended | 11.71% (Zug) | +€405,932 a year |
0 Months
Statutory register floor
3-yr cap: ≤ €1,217,796
|
| Liechtenstein | 12.5% | +€435,492 a year |
0 Months
Statutory register floor
3-yr cap: ≤ €1,306,476
|
| Cyprus | 15% | +€312,196 a year |
0 Months
Statutory register floor
3-yr cap: ≤ €936,588
|
The 3 strategic pathways · how to move
ROLE: FULL HQ MOVE Best for re-pricing your entire existing company.
Move the legal home, payroll and the team to Switzerland.
Cash. ~€180,132 / year less payroll cash-out than today
Catch. Founders and the core team must relocate their centre of life.
ROLE: NEW HIRE SCALING HUB Best for keeping current HQ, but hiring new engineers 48% cheaper.
Keep today's HQ. Hire new seats through Portugal. Existing payroll does not move.
Cash. Next hire ~€2,710/mo vs ~€5,168/mo at HQ (48% less). Existing team unchanged.
Catch. No save on the existing team. Permanent establishment (PE) risk if the hub signs customer contracts.
ROLE: IP & EXIT HOLDING Best for a €825k Exit Tax Shield and IP protection while keeping payroll local.
Keep operations at HQ. Place IP and holding in Liechtenstein.
Cash. +~€825k Exit Shield — this year's payroll does not move.
Catch. Contracts, IP and management cannot stay mixed with HQ — or HQ remains the permanent establishment (PE).
Strategic rationale
Why Switzerland
Do this: Make Switzerland the main company home. This plan lists no separate people hub.
In practice: This plan would move the main company home to Switzerland from Austria.
Why this one
Switch to Liechtenstein if labour takes a smaller share of national output there (based on OECD, ILOSTAT, Eurostat and national labour-share figures).
Do not pick Cyprus if you need straightforward company-account access, or if you need predictable rules and institutions at the level of the recommended plan, or if published rule changes currently sit on that option (based on the Human Freedom and Fragile States indices).
The seat that fits best is not the seat that earns most. On the same payroll and profit assumptions, Paraguay returns about €31,251 a year more after company tax than Switzerland. −€3,127 a year of it is payroll and €34,378 a year is the corporate rate (10% against 11.7%) — and the corporate rate carries no weight in the fit score at all. Paraguay ranks 49.1 against 90.0 on operating fit, which is why it is not the seat. Both figures are on this page and neither is a correction of the other: the ranking weighs twelve operating dimensions, the profit figure weighs payroll and corporate tax. If the profit is what you are buying, that is a reason to look at Paraguay before you accept Switzerland.
Match score 95.0 / 100.
Confidence: sourced
Section 2 · Cash-flow architecture & ROI
Money & structural risk
Relocation view at the gross you entered — 20 employees + 1 director. Estimate. Not a payslip. Occupational pension is a sourced rule, not a second cash line when it is already inside employer load.
| Line item | Austria (current) | Switzerland (target) | Annual savings (€) |
|---|---|---|---|
| Gross salaries | €1,080,000 a year | €1,080,000 a year | unchanged |
| Employer social contributions | €310,647 a year | €130,510 a year | +€180,137 a year |
| Occupational pension / Pillar 2 | needs to be clarified — BMSVG 1.53% is Abfertigung (severance), already in the AT plan employer load. It is not a 2nd-pillar occupational pension. Betriebliche Pensionskasse is contractual. | Already inside the CH plan employer load. Ueberobligatorium excluded. | To verify not a separate euro line |
| Total company cash-out | €1,390,647 a year | €1,210,510 a year | +€180,137 a year |
Calculation on assumed working profit of €2,000,000 a year (User-supplied profit_eur). Not a filing. Rates are what the company is charged.
| Line | Austria | Switzerland | Annual savings (€) |
|---|---|---|---|
| Effective corporate tax rate | 23% | 11.71% (Zug) | — |
| Corporate tax / year | €460,000 a year | €234,200 a year | +€225,800 a year |
€225,800 a year less on the working-profit calculation at Switzerland versus Austria.
Note: Corporate tax rates vary by municipality (e.g., Swiss cantons). Calculated using standard default regions (e.g., Zug).
Sourced ledger · units kept separate
EUR / yearcompany-tax items
Euro subtotal €234,200 a year
EUR payroll / yearat the gross you entered — not the ranking basis
Official average wagetypical worker, Int$ PPP — context, not ranking
Euro tax items use working profit €2,000,000 a year.
Executive country comparison
Euro tax items use your stated working profit of €2,000,000. VAT/GST is the sourced standard rate, not a euro amount — place-of-supply on your actual customers is not in this ranking.
| What we can compare today | Switzerland | Liechtenstein | Cyprus |
|---|---|---|---|
| Corporate tax on assumed working profit | €234,200 a year | €250,000 a year | €300,000 a year |
| Standard VAT/GST rate (primary) | 8.1% | 8.1% | 19% |
| Payroll cash-out (what the company pays) | Switzerland €1,210,510/yr ~1.12× company cash-out | Liechtenstein €1,165,158/yr ~1.08× company cash-out | Cyprus €1,238,451/yr ~1.15× company cash-out |
| Official average wage (typical worker, OECD / national — context) | Switzerland Int$106,532/yr (OECD 2025) | Liechtenstein CHF 88,812/yr | Cyprus Int$54,591/yr (2025) · EUR 31,260/yr |
| Labour share of national output (ULC — economy context, not a firm euro) | 69.3% of output · OECD ULCE 2025 · GDP/hour USD 116.0 PPP | 63.3% of output · Eurostat D1/GVA 2023 | 55.7% of output · Eurostat D1/GVA, SE-imputed 2025 |
| Annual company-maintenance fees | none on the published tariff | none on the published tariff | €20 a year |
This is not a full P&L. Payroll is at the gross you entered.
Note: Corporate tax rates vary by municipality (e.g., Swiss cantons). Calculated using standard default regions (e.g., Zug).
Sourced euro parts for this set are in the table. Still treat every figure as an estimate.
The recurring effect is modelled. The one-off is not — it sits in your contracts and your advisor's quote. This page states the threshold that quote has to clear.
Company-side effect of this structure: €405,937 a year (payroll €180,137 a year and corporate tax €225,800 a year).
Over 3 years the move returns €1,217,811 in total. A one-off above that does not pay back inside the horizon. That is the number your own estimate has to clear.
| If the one-off is | Break-even | Net after 3 years | Verdict |
|---|---|---|---|
| €120,000 | 3.5 months | €1,097,811 | pays back inside the horizon |
| €300,000 | 8.9 months | €917,811 | pays back inside the horizon |
| €610,000 | 18 months | €607,811 | pays back inside the horizon |
| €1,200,000 | 35.5 months | €17,811 | pays back inside the horizon |
| €1,800,000 | 53.2 months | −€582,189 | does not pay back inside the horizon |
| Line | What decides it |
|---|---|
| Relocation packages | For each person who actually moves: shipping, temporary housing, school fees, tax equalisation. Per head, negotiated, and not a statutory figure. |
| Severance and notice | For the people who do not move. Bounded by notice periods and statutory severance at today's headquarters, on the existing contracts — the old contract is the base, not the new one. |
| Recruiting the replacement team | Agency or search fees for the local hires this plan prices. Commonly quoted as a share of first-year salary. |
| Double-running payroll | Both sites live through the transition. The sourced incorporation window is the floor for that period, not the whole of it. |
| Counsel and advisor retainers | Tax and legal opinion, the permanent-establishment position, treaty confirmation. Ask for an engagement letter with a fixed quote. |
| Banking and treasury setup | Account opening, payment rails, any parallel banking during onboarding. |
Same director gross run through each seat's withholding schedule. Estimate. Not a tax assessment.
| Line | Austria | Switzerland | Gain |
|---|---|---|---|
| Gross director salary / month | ~€10,000 | same contract | |
| Spendable net / month | ~€6,190 | ~€8,340 | +~€2,150 |
| Net personal gain / year | +€25,802 a year | ||
Plan model at the employee and director gross you entered — the relocation view. Ranking TCOE uses a comparable local hire at the local wage level. Hire take-home is context. Caps differ by salary. Not a payslip. Switzerland shows ZG withholding already in spendable net, plus the higher payroll-transfer line (social + BVG, before wage tax).
| Class | Gross / month | Net / month | Employer SSC | Company cash-out | Per €1 of gross |
|---|---|---|---|---|---|
| Managing director (per head) | ~€10,000 | ~€8,340 after ZG withholding; transfer ~€8,861 before wage tax |
~€1,355 | ~€11,355 | ~1.14× |
| Employees (per head) | ~€4,000 | ~€3,528 after ZG withholding; transfer ~€3,588 before wage tax |
~€476 | ~€4,476 | ~1.12× |
| Employees × 20 | ~€80,000 | ~€70,558 | ~€9,521 | ~€89,521 | — |
| Firm total | ~€100,876 | — | |||
| Official average wage (typical worker) | Switzerland Int$106,532/yr (OECD 2025) | ||||
Plan model for a Zug hire on Quellensteuer Tarif A0N (single, no children, no church tax), Kanton Zug Steuerverwaltung Tarif AN 2026. Spendable net is after that withholding (already deducted — do not subtract Quellensteuer again). Same comparison as a DE/AT payslip net. The higher payroll-transfer line is AHV/ALV/NBUV/BVG only, before Bund/Kanton/Gemeinde. C-permit ordinary assessment often has no withholding and settles tax on the annual return. EE/ER AHV/IV/EO 5.3% and ALV 1.1% to CHF 148 200 (BSV synoptische Tabelle 1.1.2026 / ZH QS Grundlagen 2026). NBUV 1.0% employee and UVG BUV 0.1378% employer to CHF 148 200 (SUVA Basissätze 2026 class 95B A0 Büro, Stufe 37 brutto including 12.5% Verwaltung + 6.5% Verhütung; private UVG office tariffs are not a single published national rate). FAK 1.025% employer, SVA Zürich / Kanton Zürich handbook 2026. BVG: 2026 Masszahlen (entry 22 680, coordination 26 460, min coordinated 3 780, max insurable 90 720, max coordinated 64 260); old-age credits Art. 16 BVG at age band 45–54 (15% of coordinated) plus typical kasse risk 2.5% of coordinated (inside the 1–4% band), split 60/40 employer/employee (legal minimum is 50/50 on savings only). Überobligatorium excluded. At a €5 000 seat this plan load is ~1.14×. OECD AW wedge is a check only; ranking uses this plan payroll. Default model: managing director on employee payroll (personal income tax + employee and employer social-security contributions). Controlling-shareholder social-security exemption: none (AHVG Art. 4–5; WML; BGE 145 V 50). Managing shareholders of a GmbH/AG on payroll are employees; AHV/IV/EO 5.3% each on the whole relevant wage, no AHV ceiling. Dividends are AHV-free unless requalified (obviously low wage and dividend yield typically above 10% of the tax value of the holding).
Official average wage is OECD Taxing Wages (international dollars, equal purchasing power) or a national mean where OECD is silent. Scale check for a typical local worker — not your team gross, and not a ranking input.
Confidence: sourced
Visa / hire a key person
Banking and paying people
Switzerland: the Swiss SIC network (domestic Swiss payments). Getting a normal company account and paying staff across borders is not as automatic as in euro-SEPA countries. Non-resident accounts offered subject to FINMA KYC; CHF and multi-currency common.
Salary
Switzerland: official occupation band. Mid 126,616 CHF/year; with employer SSC 134,698 CHF/year.
Switzerland: ranking TCOE uses NACE J on both sides (occupation_nace).
Liechtenstein: ranking TCOE prices the director seat on the local band and the engineer seat on the country-average wage — the local engineer band is a total-compensation median (base, stock and bonus), which does not divide into the HQ's gross-wage table.
Cyprus: ranking TCOE uses NACE J on both sides (occupation_nace).
Section 3 · Risk matrix & legal safeguards
Strategic trade-offs & risk matrix
Seven risk areas from the stored facts for Switzerland. Green — clear path = sourced and unproblematic at this profile. Yellow — management required = normal for this country set, handled by process. Red — dealbreaker risk = a decision or an external confirmation is needed before the structure is committed.
| Risk area | Status | What the stored data shows | Board action before signing |
|---|---|---|---|
| Tax compliance & permanent-establishment risk (OECD Art. 5) | Yellow — management required | Stored band: medium — typical, same band as Liechtenstein and Cyprus. | Name the person who may conclude customer contracts in Switzerland and keep that authority with the legal home until counsel signs off. |
| Substance & place of management | Red — dealbreaker risk | This plan moves the legal home from Austria to Switzerland. OR Art. 814(3) (GmbH) / Art. 718(4) (AG): the company must be representable by a person resident in Switzerland who is a managing director or manager and has access to the capital-contribution and beneficial-owner registers. OR Art. 777 / Art. 626: the articles name the seat (Sitz) in Switzerland. A c/o address is not evidence of effective management. The stored residence test is not met from today’s headquarters — name directors who meet the statutory residence rule or seek any available exemption. | Minute where strategic decisions are taken, and place at least one decision-maker where the seat is. A c/o address is not substance. |
| Banking & KYC onboarding | Yellow — management required | Switzerland: the Swiss SIC network (domestic Swiss payments). Getting a normal company account and paying staff across borders is not as automatic as in euro-SEPA countries. Non-resident accounts offered subject to FINMA KYC; CHF and multi-currency common. Onboarding SLA: not published GwG / FINMA Circ. 2016/7 require CDD before the business relationship is used; FINMA publishes no company-account onboarding day-count. Source: SR 955.0 GwG; FINMA-RS 2016/7. https://www.finma.ch. | Start account onboarding before payroll registration; a seat without a working account cannot pay salaries on time. |
| Visa & work-permit path | Green — clear path | EU/EFTA staff: free-movement path. Non-EU staff: federal quotas — slower, not guaranteed. Stated wait: 56 days — published waiting-time guide, not a statutory decision deadline (Swiss SEM). SEM FAQ (updated 5 Jul 2026): in our experience six to eight weeks for the full canton + SEM file. Stored 56 days is that published upper guide, not a statutory decision deadline. Quotas and first-time employers can run longer. https://www.sem.admin.ch/sem/en/home/themen/arbeit/faq.0010.html | Confirm the quota or permit class for every non-local key hire before you commit relocation dates. |
| Payroll process metrics | Yellow — management required | Employer load in Switzerland is modelled at ~1.12× gross from the statutory schedule, not read off a payslip. Caps and contribution classes are applied at the gross you entered. | Have the payroll provider restate the employer load on the actual contracts before the budget is locked. |
| Treaty position in this structure | Yellow — management required | Austria × Switzerland on file. Day-counts are stored per pair. | Have counsel confirm the current double-tax agreement text and any MLI reservation for every pair you will actually use. |
| Budget completeness | Green — clear path | Every euro line in this structure is sourced; no cost item is missing from the calculation. | Re-check the sourced lines at the next knowledge-base refresh. |
Home country exit & anti-abuse checklist
Everything before this page prices a destination. This page is the country you are leaving. Its rules do not change what a seat costs — they change whether the saving survives. What sets them off is something about the destination: its tax rate for most origins, and for the Netherlands whether the state is on a published list. Either way the question belongs next to the seat, not after it.
| What it means | Rule on file | Seat that triggers it | Action before the move date |
|---|---|---|---|
| Home-country tax trap: retained profits | § 10a KStG — Hinzurechnungsbesteuerung (CFC) | Switzerland | Does the destination's effective burden fall below 15% once refunds are counted, is the holding controlled within the meaning of § 10a, and does the substance carve-out apply on the intended setup? |
| Owner exit tax on unrealised company value | § 27 Abs 6 EStG — Wegzugsbesteuerung on privately held shares | Switzerland | What are the unrealised gains on the shareholding at the intended move date, is the destination inside the EU/EEA for the deferral, and what security or reporting does the tax office require? |
| Home-country tax trap: retained profits | § 10a KStG — Hinzurechnungsbesteuerung (CFC) | Liechtenstein | Does the destination's effective burden fall below 15% once refunds are counted, is the holding controlled within the meaning of § 10a, and does the substance carve-out apply on the intended setup? |
| Owner exit tax on unrealised company value | § 27 Abs 6 EStG — Wegzugsbesteuerung on privately held shares | Liechtenstein | What are the unrealised gains on the shareholding at the intended move date, is the destination inside the EU/EEA for the deferral, and what security or reporting does the tax office require? |
| Owner exit tax on unrealised company value | § 27 Abs 6 EStG — Wegzugsbesteuerung on privately held shares | Cyprus | What are the unrealised gains on the shareholding at the intended move date, is the destination inside the EU/EEA for the deferral, and what security or reporting does the tax office require? |
| Seat | Rule | Status | Why it fires | Question for counsel |
|---|---|---|---|---|
| Switzerland | § 10a KStG — Hinzurechnungsbesteuerung (CFC) | Checkpoint | Switzerland is taxed at 11.71% against Austria's 15% low-tax line. Applies to financial years beginning after 31 December 2025. | Does the destination's effective burden fall below 15% once refunds are counted, is the holding controlled within the meaning of § 10a, and does the substance carve-out apply on the intended setup? |
| Switzerland | § 27 Abs 6 EStG — Wegzugsbesteuerung on privately held shares | Strategic action required | Switzerland is outside the EU/EEA, so § 27 Abs 6 EStG does not open that route on the same terms. Confirm the position before the move date is set. | What are the unrealised gains on the shareholding at the intended move date, is the destination inside the EU/EEA for the deferral, and what security or reporting does the tax office require? |
| Liechtenstein | § 10a KStG — Hinzurechnungsbesteuerung (CFC) | Checkpoint | Liechtenstein is taxed at 12.5% against Austria's 15% low-tax line. Applies to financial years beginning after 31 December 2025. | Does the destination's effective burden fall below 15% once refunds are counted, is the holding controlled within the meaning of § 10a, and does the substance carve-out apply on the intended setup? |
| Liechtenstein | § 27 Abs 6 EStG — Wegzugsbesteuerung on privately held shares | Checkpoint | Liechtenstein is inside the EU/EEA, so the deferral route in § 27 Abs 6 EStG is open on application. Confirm the position before the move date is set. | What are the unrealised gains on the shareholding at the intended move date, is the destination inside the EU/EEA for the deferral, and what security or reporting does the tax office require? |
| Cyprus | § 27 Abs 6 EStG — Wegzugsbesteuerung on privately held shares | Checkpoint | Cyprus is inside the EU/EEA, so the deferral route in § 27 Abs 6 EStG is open on application. Confirm the position before the move date is set. | What are the unrealised gains on the shareholding at the intended move date, is the destination inside the EU/EEA for the deferral, and what security or reporting does the tax office require? |
Sources: BDO, Austria — Low Taxation Threshold for Anti-Abuse Rules Raised to 15%; § 10a KStG · § 27 Abs 6 EStG; ICON Wirtschaftstreuhand, Verschärfung bei der Wegzugsbesteuerung (2026). Position as at 2026-09. Confirm against the current text before the move date is set.
OECD Article 5 board questions for Switzerland. A treaty on file does not make a local team safe.
| Test | Must the board settle this before signing? |
|---|---|
| Fixed place of business (Art. 5(1)) | Where are customer contracts signed and where does day-to-day management sit? |
| Home-office PE (OECD commentary) | Does the company require, equip, or systematically use a director or key person’s home as the office? |
| Dependent-agent PE (Art. 5(5)) | Who has authority to bind the company in the hub country? |
| Independent-agent exception (Art. 5(6)) | Is any local representative genuinely independent, or economically dependent on this group? |
| Service-PE / day-count (treaty overlay) | How many days do decision-makers and delivery staff spend in the other state? |
| Force of attraction | Does the stored PE sentence for this country mention force of attraction or a short-duration services PE? |
| Seat in this ranking | PE band | Versus the other options | Basis |
|---|---|---|---|
| Switzerland | medium | typical, same band as Liechtenstein and Cyprus | KB PE level (OECD Art. 5 mapping / PwC country paragraph) |
| Liechtenstein | medium | typical, same band as Switzerland and Cyprus | KB PE level (OECD Art. 5 mapping / PwC country paragraph) |
| Cyprus | medium | typical, same band as Switzerland and Liechtenstein | KB PE level (OECD Art. 5 mapping / PwC country paragraph) |
| Item | What is stored |
|---|---|
| Local director / resident manager | OR Art. 814(3) (GmbH) / Art. 718(4) (AG): the company must be representable by a person resident in Switzerland who is a managing director or manager and has access to the capital-contribution and beneficial-owner registers. |
| Physical office / registered premises | OR Art. 777 / Art. 626: the articles name the seat (Sitz) in Switzerland. A c/o address is not evidence of effective management. |
| Tax residence / place of management | DBG Art. 50: a company is resident where it has its statutory seat or effective management. A treaty tie-breaker can displace domestic residence. Minute where strategic decisions are taken. Resolutions signed only on paper at Switzerland while decisions are taken elsewhere is a facts-and-circumstances PE and residence question for counsel. Source: https://www.fedlex.admin.ch/eli/cc/27/317_321_377/de. |
| Banking KYC | Switzerland: the Swiss SIC network (domestic Swiss payments). Getting a normal company account and paying staff across borders is not as automatic as in euro-SEPA countries. Non-resident accounts offered subject to FINMA KYC; CHF and multi-currency common. Onboarding SLA: not published GwG / FINMA Circ. 2016/7 require CDD before the business relationship is used; FINMA publishes no company-account onboarding day-count. Source: SR 955.0 GwG; FINMA-RS 2016/7. https://www.finma.ch. |
| Corporate-tax communal multiplier (Zurich vs Zug) | Default seat Zug (Stadt Zug) combined CIT 2026: 11.71%. Zurich (Stadt Zürich): 19.47%. Combined Bund + Kanton + Gemeinde at the Hauptort, without church tax. Source: KPMG Clarity on Swiss Taxes 2026. Not a nationwide 12% lump. |
Gantt-style checklist for the recommended structure — setup, banking / KYC, then residency and substance.
Phase gate: notarised deed and register extract in hand, shareholder register issued, beneficial-owner filing accepted. No supervised bank opens an account on a promise of registration.
Phase gate: operating account live with outbound payment rights, payroll provider engaged, one test salary run reconciled.
Phase gate: permits filed for each relocating key person, contract-signature and board authority documented at the new seat, opening tax registration confirmed in writing. A tax authority asks for this evidence later; it has to be created now.
This sequence is a structured orientation from your profile and sourced country facts. Authority processing times, visa decisions and bank onboarding depend on local providers.
Profit after corporate tax, on the working profit you stated. Year one is this team at this pay. Steady state is the same company recruiting at local wages.
Today in Austria: €2,000,000 working profit, €1,540,000 after 23% corporate tax, on payroll of €1,390,647.
| Seat | CIT at company level | Profit after tax · year 1 | Profit after tax · steady state | Local pay level |
|---|---|---|---|---|
| Switzerland | 11.71% (Zug) | €1,924,843 +€384,843 |
€1,778,137 +€238,137 |
×1.843 pay does not hold |
| Liechtenstein | 12.5% | €1,947,303 +€407,303 |
€1,768,173 +€228,173 |
×1.572 pay does not hold |
| Cyprus | 15% | €1,829,367 +€289,367 |
€1,716,677 +€176,677 |
×0.743 |
Working profit is your figure. Corporate tax is a rate applied to it, not a filing.
Appendix · MultiBaseIQ
Every figure below is what you entered on the company form. This is the profile the engine used.
External Counsel Briefing Memorandum
One-pager of engine facts to hand to tax or legal counsel. Estimate. Counsel verifies primary law. Structure match score 95.0 / 100.
| Pair | Treaty | Art. 5-style service days | Source |
|---|---|---|---|
| Austria × Switzerland | yes | none in the sourced Art. 5 | RIS BGBl. Nr. 64/1975 (signed Vienna 30 Jan 1974) Art. 5: OECD-style fixed place + dependent agent; construction/installation listed as a PE if duration exceeds 12 months; no service-PE day-count. Later protocols (1995/2001/2007) do not rewrite Art. 5 as a services PE. https://www.ris.bka.gv.at/GeltendeFassung.wxe?Abfrage=Bundesnormen&Gesetzesnummer=10004202 (1974) |
| Austria × Portugal remote hub | yes | none in the sourced Art. 5 | RIS BGBl. Nr. 85/1972 (signed Vienna 29 Dec 1970) Art. 5: OECD-style fixed place + dependent agent; construction/installation listed as a PE if duration exceeds 12 months; no service-PE day-count. Art. 7 is attribution-only (no force of attraction). https://www.ris.bka.gv.at/GeltendeFassung.wxe?Abfrage=Bundesnormen&Gesetzesnummer=10004117 (1970) |
| Austria × Liechtenstein holding split | yes | none in the sourced Art. 5 | RIS BGBl. Nr. 24/1971 (signed 5 Nov 1969, in force 7 Dec 1970) Art. 5: OECD-style fixed place + dependent agent; construction/installation listed as a PE if duration exceeds 12 months; no service-PE day-count. Art. 7 is attribution-only. Protocols (2013 / BGBl. III Nr. 8/2017) amend residence and EOI, not Art. 5 as a services PE. https://www.ris.bka.gv.at/GeltendeFassung.wxe?Abfrage=Bundesnormen&Gesetzesnummer=10004088 (1971) |
Not legal verification of the pair. Counsel confirms the current text.
Dated PE, entity or payroll rule changes on the recommended home or next option
Each line is a field this engine does not carry, restated as a work item. Nothing here is an estimate we are withholding.
Plan model at the gross you entered — ~€4,000 / month per employee and ~€10,000 / month per director, for the recommended home and the next two options. Amounts in euro use the stored ECB (or peg) table. Caps and progression differ by salary. Not a payslip. This table is the relocation view at the typed gross; ranking TCOE uses a comparable local hire at the local wage level.
| Line | Switzerland | Liechtenstein | Cyprus |
|---|---|---|---|
| Employee social contributions | AHV/IV/EO 5.3%~€2,544 | AHV/IV/FAK/VK 4.90%~€2,352 | ~€458 |
| Employer social contributions | AHV/IV/EO 5.3%~€2,544 | AHV/IV/FAK/VK 7.385%~€3,545 | ~€616 |
| Unemployment employee | ALV 1.1% cap CHF 148,200~€528 | ALV 0.5% cap CHF 126 000~€240 | Inside the social-contribution line in this model |
| Unemployment employer | ALV 1.1%~€528 | ALV 0.5%~€240 | Inside the employer social-contribution line in this model |
| Occupational pension | BVG Pillar 2 estimate · age 45-54, employer share 60%, typical kasse risk; Ueberobligatorium excluded~€3,471 | kasse-specific BPVG is mandatory occupational. Statutory floor 8% of insured wage, employer at least half. Kasse sets the rate. 2026 entry CHF 14,700; max insured CHF 88,200; coordination deduction CHF 0. Do not copy the Swiss BVG estimate. | not generally mandatory (private sector) No national statutory occupational rate for private-sector payroll. Social Insurance is the stored employer load. Branch / public-sector schemes are not the default. |
| Wage / withholding tax | Quellensteuer ZG A0N 1.51%~€725 | Landessteuer 1.2% of taxable + Vaduz Zuschlag 150%~€1,362 | ~€470 |
| Municipal / communal multiplier | Zug plan model — Tarif A, single, no children, no church tax. Federal AHV/ALV/BVG rates do not change by canton. FAK is the SVA Zürich handbook rate. | Vaduz Gemeindesteuerzuschlag 150% of Landessteuer (default seat, 2026). Other sourced Gemeinden: Balzers 150%, Ruggell 150%, Mauren 160%, Eschen 160%. Remaining (Schaan 150%, Triesen 150%, Triesenberg 150%, Gamprin 150%, Schellenberg 150%, Planken 150%) from the 2026 budget summary (secondary). Field is per municipality, not per ISO. | none on this tax Cyprus has no municipal tax on employment income and no communal multiplier on PAYE. Municipal charges are on property, not the payslip. PAYE is central (Tax Department). |
| Company cash-out / month | ~€4,476 | ~€4,315 | ~€4,616 |
| Spendable net / month | ~€3,528 | ~€3,670 | ~€3,072 |
| Employer multiple | ~1.12× | ~1.08× | ~1.15× |
Switzerland: Plan model for a Zug hire on Quellensteuer Tarif A0N (single, no children, no church tax), Kanton Zug Steuerverwaltung Tarif AN 2026. Spendable net is after that withholding (already deducted — do not subtract Quellensteuer again). Same comparison as a DE/AT payslip net. The higher payroll-transfer line is AHV/ALV/NBUV/BVG only, before Bund/Kanton/Gemeinde. C-permit ordinary assessment often has no withholding and settles tax on the annual return. EE/ER AHV/IV/EO 5.3% and ALV 1.1% to CHF 148 200 (BSV synoptische Tabelle 1.1.2026 / ZH QS Grundlagen 2026). NBUV 1.0% employee and UVG BUV 0.1378% employer to CHF 148 200 (SUVA Basissätze 2026 class 95B A0 Büro, Stufe 37 brutto including 12.5% Verwaltung + 6.5% Verhütung; private UVG office tariffs are not a single published national rate). FAK 1.025% employer, SVA Zürich / Kanton Zürich handbook 2026. BVG: 2026 Masszahlen (entry 22 680, coordination 26 460, min coordinated 3 780, max insurable 90 720, max coordinated 64 260); old-age credits Art. 16 BVG at age band 45–54 (15% of coordinated) plus typical kasse risk 2.5% of coordinated (inside the 1–4% band), split 60/40 employer/employee (legal minimum is 50/50 on savings only). Überobligatorium excluded. At a €5 000 seat this plan load is ~1.14×. OECD AW wedge is a check only; ranking uses this plan payroll.
Liechtenstein: AHV/IV/FAK/VK from 1.1.2026 (EE 4.90% / ER 7.385%) + ALV 0.5/0.5 to CHF 126 000. Landessteuer 1.2% of taxable + Vaduz Zuschlag 150% (Gemeinde Vaduz Voranschlag 2026). BVG not in the default (occupational, not a uniform statutory rate).
Cyprus: EE SI 8.8 + GESY 2.65; ER SI 8.8 + GESY 2.90 + redundancy 1.2 + HRDA 0.5 + cohesion 2.0. SIS ceiling EUR 68 904 (2026).
Confidence: sourced
Euro tax items use your stated working profit of €2,000,000. VAT/GST is the sourced standard rate, not a euro amount — place-of-supply on your actual customers is not in this ranking.
| What we can compare today | Switzerland | Liechtenstein | Cyprus |
|---|---|---|---|
| Corporate tax on assumed working profit | €234,200 a year | €250,000 a year | €300,000 a year |
| Standard VAT/GST rate (primary) | 8.1% | 8.1% | 19% |
| Payroll cash-out (what the company pays) | Switzerland €1,210,510/yr ~1.12× company cash-out | Liechtenstein €1,165,158/yr ~1.08× company cash-out | Cyprus €1,238,451/yr ~1.15× company cash-out |
| Official average wage (typical worker, OECD / national — context) | Switzerland Int$106,532/yr (OECD 2025) | Liechtenstein CHF 88,812/yr | Cyprus Int$54,591/yr (2025) · EUR 31,260/yr |
| Labour share of national output (ULC — economy context, not a firm euro) | 69.3% of output · OECD ULCE 2025 · GDP/hour USD 116.0 PPP | 63.3% of output · Eurostat D1/GVA 2023 | 55.7% of output · Eurostat D1/GVA, SE-imputed 2025 |
| Annual company-maintenance fees | none on the published tariff | none on the published tariff | €20 a year |
This is not a full P&L. Payroll is at the gross you entered.
Note: Corporate tax rates vary by municipality (e.g., Swiss cantons). Calculated using standard default regions (e.g., Zug).
Sourced euro parts for this set are in the table. Still treat every figure as an estimate.
Plan model at the employee and director gross you entered — the relocation view. Ranking TCOE uses a comparable local hire at the local wage level. Hire take-home is context. Caps differ by salary. Not a payslip. Switzerland shows ZG withholding already in spendable net, plus the higher payroll-transfer line (social + BVG, before wage tax).
| Class | Gross / month | Net / month | Employer SSC | Company cash-out | Per €1 of gross |
|---|---|---|---|---|---|
| Managing director (per head) | ~€10,000 | ~€8,340 after ZG withholding; transfer ~€8,861 before wage tax |
~€1,355 | ~€11,355 | ~1.14× |
| Employees (per head) | ~€4,000 | ~€3,528 after ZG withholding; transfer ~€3,588 before wage tax |
~€476 | ~€4,476 | ~1.12× |
| Employees × 20 | ~€80,000 | ~€70,558 | ~€9,521 | ~€89,521 | — |
| Firm total | ~€100,876 | — | |||
| Official average wage (typical worker) | Switzerland Int$106,532/yr (OECD 2025) | ||||
Plan model for a Zug hire on Quellensteuer Tarif A0N (single, no children, no church tax), Kanton Zug Steuerverwaltung Tarif AN 2026. Spendable net is after that withholding (already deducted — do not subtract Quellensteuer again). Same comparison as a DE/AT payslip net. The higher payroll-transfer line is AHV/ALV/NBUV/BVG only, before Bund/Kanton/Gemeinde. C-permit ordinary assessment often has no withholding and settles tax on the annual return. EE/ER AHV/IV/EO 5.3% and ALV 1.1% to CHF 148 200 (BSV synoptische Tabelle 1.1.2026 / ZH QS Grundlagen 2026). NBUV 1.0% employee and UVG BUV 0.1378% employer to CHF 148 200 (SUVA Basissätze 2026 class 95B A0 Büro, Stufe 37 brutto including 12.5% Verwaltung + 6.5% Verhütung; private UVG office tariffs are not a single published national rate). FAK 1.025% employer, SVA Zürich / Kanton Zürich handbook 2026. BVG: 2026 Masszahlen (entry 22 680, coordination 26 460, min coordinated 3 780, max insurable 90 720, max coordinated 64 260); old-age credits Art. 16 BVG at age band 45–54 (15% of coordinated) plus typical kasse risk 2.5% of coordinated (inside the 1–4% band), split 60/40 employer/employee (legal minimum is 50/50 on savings only). Überobligatorium excluded. At a €5 000 seat this plan load is ~1.14×. OECD AW wedge is a check only; ranking uses this plan payroll. Default model: managing director on employee payroll (personal income tax + employee and employer social-security contributions). Controlling-shareholder social-security exemption: none (AHVG Art. 4–5; WML; BGE 145 V 50). Managing shareholders of a GmbH/AG on payroll are employees; AHV/IV/EO 5.3% each on the whole relevant wage, no AHV ceiling. Dividends are AHV-free unless requalified (obviously low wage and dividend yield typically above 10% of the tax value of the holding).
Official average wage is OECD Taxing Wages (international dollars, equal purchasing power) or a national mean where OECD is silent. Scale check for a typical local worker — not your team gross, and not a ranking input.
Confidence: partial
Risk that a tax authority treats a local team as a taxable local company: typical, same band as Liechtenstein and Cyprus.
Your sales model is mixed. Taxable-presence questions sit in where people work, where contracts are signed, and where local operations sit.
A tax treaty is on file for Austria and Switzerland in this structure. That does not make a local team safe.
| Switzerland | Liechtenstein | Cyprus | |
|---|---|---|---|
| Taxable-presence risk | typical, same band as Liechtenstein and Cyprus | typical, same band as Switzerland and Cyprus | typical, same band as Switzerland and Liechtenstein |
PE, entity and payroll rule changes that hit this recommendation or the next option
1 published rule change touch the recommended structure’s countries.
Austria — § 10a KStG (Corporate Income Tax Act) — Hinzurechnungsbesteuerung (CFC / controlled-foreign-company rules): the low-taxation line for Austrian-controlled foreign companies is 15% for financial years beginning after 31 December 2025. Low taxation is met at a nominal OR effective rate below 15%, and expressly also where the burden falls below 15% because of refunds or reductions — so a destination whose headline rate clears 15% can still be caught once a shareholder refund is applied. Control is more than 50% of shares, voting rights or profit entitlement, directly or indirectly. The substance carve-out is unchanged. 2026-01-01 · in force · § 10a KStG; BDO Austria — Low Taxation Threshold for Anti-Abuse Rules Raised to 15%
Switzerland — First Swiss QDMTT (nationale Ergänzungssteuer / national supplementary tax) returns are due 30 June 2026 for calendar-year groups (18 months after FY 2024). QDMTT has applied since 1 January 2024 and the IIR international top-up since 1 January 2025 for MNE groups with consolidated revenue ≥ EUR 750m; the Federal Council has not brought the UTPR into force. Filing is electronic via OMTax after unsolicited registration. Cantonal corporate tax for groups below the threshold — including typical Zug ~11.8–15% GmbH/AG rates and lump-sum taxation for individuals — is unchanged. Subsequent years: 15 months after year-end. 2026-06-30 · in force · Federal Department of Finance, OECD minimum tax implementation; ESTV Ergänzungssteuer / OMTax; Canton of Zug OECD-Mindestbesteuerung (filing deadline)
Austria — Budgetbegleitgesetz (Budget Accompanying Act) 2027–2028 (Nationalrat / National Council 8 July 2026, Bundesrat / Federal Council 16 July 2026): the standard 23% corporate tax stays. For financial years beginning after 31 December 2027, income above EUR 1,000,000 is taxed at 24% (group tax looks at the whole Gruppeneinkommen / group income). Limited-tax foreign corporations under § 1 (3) Z 1 (item 1) KStG (Corporate Income Tax Act) follow the same band; public-law and charitable bodies under Z 2/3 (items 2/3) stay at 23%. 2026/27 corporate tax remains a flat 23%. capital withholding tax 27.5% and top personal income tax 55% (until 2029) are unchanged. 2028-01-01 · planned · Budgetbegleitgesetz 2027–2028; KPMG Austria Reporting News August 2026; PwC WTS Austria corporate tax
Same engine, same knowledge base. The purchased dossier is this artefact computed on the company you enter — not a longer version of a teaser.