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MultiBaseIQ MULTIBASE IQ CORPORATE DOSSIER

MULTIBASE IQ CORPORATE DOSSIER

2026-09-18 · ID MBQ-86C414811B85

Executive Board Summary & Strategic Decision Matrix

21 people on payroll · current headquarters Austria · model mixed · revenue €10–50m · knowledge base 2026-09-18

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

  • Company Payroll Savings ~€180,132/yr
  • Corporate Tax Savings ~€225,800/yr

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

Live alternatives as a main home

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

Management notes

  • Rates. Stored default regions (e.g. Zug). The exact municipality moves the figure.
  • Cash. Payroll cash-out plus corporate tax versus today's HQ. One-off costs sit on the investment page.
  • Catch. The tax case needs substance: a decision-maker and customer contracts at the new seat.

The 3 strategic pathways · how to move

Three paths from Austria

How the 3 Pathways work

We test 3 fundamentally different business strategies for your growth. The country on each card is selected specifically for that strategy:

  • Option 1: Complete HQ Relocation → Moves the whole company to your #1 ranked seat (Switzerland).
  • Option 2: Remote Talent Hub → Keeps current HQ as-is, but opens a nearshore hub (Portugal) to cut hiring costs for new hires.
  • Option 3: Hybrid Holding Split → Keeps team at HQ, but places an IP/Holding entity in a top legal home (Liechtenstein).

ROLE: FULL HQ MOVE Best for re-pricing your entire existing company.

Maximum cash effectRecommended

Option 1: Complete HQ relocation to Switzerland

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.

Low-friction scaling

Option 2: Keep Austria HQ + add a remote hub in Portugal

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.

IP & exit protection

Option 3: Hybrid split (holding in Liechtenstein + operating hub in Austria)

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

Seat

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

  • Deep tech talent pool (based on the Global Innovation Index).
  • Straightforward company-account access (checked against non-resident opening standards).
  • Working hours overlap a full standard day with your current headquarters.

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

Company P&L impact — three cash buckets

Bucket 1 · Company payroll savings (operating)

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 yearunchanged
Employer social contributions€310,647 a year€130,510 a year+€180,137 a year
Occupational pension / Pillar 2needs 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

Bucket 2 · Corporate tax advantage (company)

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).

Corporate tax against the recommendation

Switzerland is also the lowest of the three options on corporate tax, at 11.71% (Zug) on €2,000,000 a year working profit (User-supplied profit_eur). The match score and the profit layer point the same way here.

OptionRateCorporate tax / yearStructure match
Switzerland · recommended 11.71% (Zug) €234,200 a year 95
Liechtenstein 12.5% €250,000 a year 84.8
Cyprus 15% €300,000 a year 71.7

Note: Corporate tax rates vary by municipality (e.g., Swiss cantons). Calculated using standard default regions (e.g., Zug).

Compact executive grid — payroll and Corporate Income Tax (CIT) side by side

Sourced ledger · units kept separate

EUR / yearcompany-tax items

  • Corporate income tax on working profit€234,200 a year
  • Annual entity compliance feesnone

Euro subtotal €234,200 a year

EUR payroll / yearat the gross you entered — not the ranking basis

  • Payroll: company cash-out at plan gross€1,210,510 a yearhire keeps €946,778 a year

Official average wagetypical worker, Int$ PPP — context, not ranking

  • Official average wage (context, not ranking)Switzerland Int$106,532/yr (OECD 2025)

Euro tax items use working profit €2,000,000 a year.

Money

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 todaySwitzerlandLiechtensteinCyprus
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-outLiechtenstein €1,165,158/yr ~1.08× company cash-outCyprus €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/yrCyprus 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 PPP63.3% of output · Eurostat D1/GVA 202355.7% of output · Eurostat D1/GVA, SE-imputed 2025
Annual company-maintenance feesnone on the published tariffnone 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.

What the move may cost before it stops paying back

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.

The threshold

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 isBreak-evenNet after 3 yearsVerdict
€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

What your estimate has to contain

LineWhat decides it
Relocation packagesFor each person who actually moves: shipping, temporary housing, school fees, tax equalisation. Per head, negotiated, and not a statutory figure.
Severance and noticeFor 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 teamAgency or search fees for the local hires this plan prices. Commonly quoted as a share of first-year salary.
Double-running payrollBoth sites live through the transition. The sourced incorporation window is the floor for that period, not the whole of it.
Counsel and advisor retainersTax and legal opinion, the permanent-establishment position, treaty confirmation. Ask for an engagement letter with a fixed quote.
Banking and treasury setupAccount opening, payment rails, any parallel banking during onboarding.

Bucket 3 · Founder personal net cash (director layer)

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

Payroll at your entered gross (estimate) in Switzerland

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).

ClassGross / monthNet / month Employer SSCCompany cash-outPer €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)

Employer Cost Factor: ~1.14x. For every €1.00 gross salary paid to the employee, budget ~€1.14 in total company costs.

Reference €5,000 seat estimate; the actual factor varies by gross salary, role and contribution caps.

Next Steps: Use this factor for high-level business planning. Forward the detailed calculation basis below to your local tax advisor or Employer of Record (EOR).

🔽 View Expert Details & Calculation Basis

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.

People

Confidence: sourced

Visa / hire a key person

  • Switzerland: EU/EFTA: free movement. Non-EU: quota system (typical wait ca. 56 days).
  • Liechtenstein: EEA free movement, but strict quotas. Third-country ca. 90 days.
  • Cyprus: EU: free movement. Non-EU: EU Blue Card / national work-permit (ca. 90 days).

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

Operational & regulatory risk radar

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 areaStatusWhat the stored data showsBoard 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.

Tax Counsel Advice

Every “to verify” field in this matrix is a work item for local counsel, not an estimate this engine is withholding. Hand the counsel briefing memorandum at the end of this dossier to your advisor together with this page.

Home country exit & anti-abuse checklist

What Austria does when you leave

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.

Problem–solution matrix

What it meansRule on fileSeat that triggers itAction 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?
SeatRuleStatusWhy it firesQuestion 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?

Tax Counsel Advice

Rules of the country you are leaving. Each is a work item for counsel, not a calculation — this engine states the trigger and the question and does not opine. A controlled-foreign-company charge does not stop a move; it can move the profit back into the Austria tax base, which would undo the corporate-tax part of the case on the previous pages. Exit tax lands on the owner personally and is due on a gain nobody has realised. Both are answerable in advance and neither is answerable by this engine.

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.

Tax compliance checklist

OECD Article 5 board questions for Switzerland. A treaty on file does not make a local team safe.

TestMust 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 attractionDoes the stored PE sentence for this country mention force of attraction or a short-duration services PE?
Seat in this rankingPE bandVersus the other optionsBasis
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)

Switzerland substance checklist

ItemWhat is stored
Local director / resident managerOR 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 premisesOR 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 managementDBG 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 KYCSwitzerland: 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.

90-day sequence

Gantt-style checklist for the recommended structure — setup, banking / KYC, then residency and substance.

Day 1Day 30Day 60Day 90

Days 1–30 · Corporate Structure & Incorporation

  • Incorporate in Switzerland Start the GmbH with local counsel. Published typical incorporation window: ca. 10–14 days (published typical, not a legal SLA). People placed here in the model: 20 employees and 1 director.

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.

Days 31–60 · Banking, KYC onboarding, and Employer of Record (EOR) / Direct Payroll

  • Open company accounts in Switzerland Start company-account onboarding. Stored payment rails: the Swiss SIC network (domestic Swiss payments). Non-resident company accounts and cross-border payroll are not automatic — confirm access with counsel. Non-resident accounts offered subject to FINMA KYC; CHF and multi-currency common.
  • Proceed with own-entity payroll Employer of Record (EOR) is off on this profile. Plan local payroll on the entities above.

Phase gate: operating account live with outbound payment rights, payroll provider engaged, one test salary run reconciled.

Days 61–90 · Tax Residency Transfer, Work-Permit Approvals & Substance Filing

  • Confirm the hire path in Switzerland 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
  • Take the primary corporate-tax rate to counsel 11.71% (Zug) corporate tax on file → €234,200 a year on the working-profit assumption. Switzerland: the stored corporate-tax rate is the canton of Zug (11.71%), the engine default because it is the lowest ordinary rate in the country. Another canton changes the figure substantially — Zurich 19.47% and Bern 20.54%, up to about 1.8× the default, i.e. 8.8 points of working profit on the same company and the same payroll. Communal multipliers move it again inside a canton. Additional cantonal taxes — capital tax, the owner's tax on a dividend, the STAF patent-box relief — are not computed: they depend on the exact company seat, and a canton other than the stored default was not stated. Fix the canton before this figure decides anything.
  • Confirm the primary VAT/GST rate with counsel 8.1% standard rate on file. Place-of-supply and your actual customer mix are not in this ranking.

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.

What the move earns

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.

SeatCIT 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

What reaches you — three stages, not one number

Corporate tax is stage 1 and is already in the profit column. Stage 2 is withholding at the seat after the parent-subsidiary directive or Art. 10 of the treaty that was actually read. Stage 3 is Austria KESt 27.5% with a credit for that withholding. The holding column assumes a qualifying company, a 100% holding and substance — it is not read off the form. None of these rates enters the ranking.

Seat Domestic WHT WHT · natural person WHT · holding Combined · NP Combined · holding
Switzerland 35% 15%
Art. 10 portfolio
0%
Art. 10 participation
27.5% 27.5%
Liechtenstein 0% 15%
Art. 10 portfolio
0%
Art. 10 participation
27.5% 27.5%
Cyprus 0% unread 0%
EU parent-subsidiary
unread 27.5%

Where the combined figure equals the residence rate, that is the credit method working, not a missing layer: Switzerland's 35% statutory withholding never reaches an Austrian owner — Art. 10 caps it at 15%, and the credit absorbs that 15%. The two paths only diverge when the seat rate sits above the residence rate, and no readable pair in this knowledge base currently does.

Unread Art. 10 cells stay unread. The domestic cell is not used as if it were the treaty rate.

Working profit is your figure. Corporate tax is a rate applied to it, not a filing.

Appendix · MultiBaseIQ

Your inputs for this report

Every figure below is what you entered on the company form. This is the profile the engine used.

Company snapshot

Employees (count)
20
Typical monthly gross per employee
€4,000
Managing directors (count)
1
Typical monthly gross per director
€10,000
Jurisdictions already used
1
Revenue model
Mixed
Industry / business type
Enterprise SaaS
Preferred settlement type
Small city (50k–1M)
Revenue band
€10–50m
Annual working profit
€2,000,000

Current distribution

Primary HQ today
Austria
Employee countries
Austria
Headcount % in primary HQ
100%
Foreign hubs: own company or outside employer
Our own company in each country

What you are moving

Migration strategy
Not decided yet — scored as a founder & holding relocation, which claims no wage saving
Employees moving with you
Not stated — directors only
Where the revenue comes from
Europe 100%
Estimated company value growth
€3,000,000
Software & tech revenue share
100%
Annual profit payout as dividends
20%

Appendix · continued

What matters most

Total cost of employment
Must
Profit kept after corporate tax
Must
Unit labour cost
Important
Permanent establishment risk
Important
Talent access (tech/product)
Must
Company banking access
Important
Financial-sector freedom
Important
Visa and relocation friction
Important
Entity setup and maintenance
Important
Time zone overlap
Important
Governance and regulatory stability
Important
Market access (barrier-free market)
Important

Constraints

EU core
Neutral
Eastern EU
Ignore
USA
Preferred
Anglosphere
Ignore
EFTA & microstates
Preferred
Gulf states
Ignore
West-aligned Asia
Neutral
South/Latin America + Mexico
Neutral
Hard exclusions
None
Max additional hubs
2

External Counsel Briefing Memorandum

For your advisor

To
CFO / tax counsel (external)
From
MultiBaseIQ engine · named profile only
Date
2026-09-18
Subject
Seat, payroll cash-out, PE band and sourced statutory references for Switzerland (CH)

One-pager of engine facts to hand to tax or legal counsel. Estimate. Counsel verifies primary law. Structure match score 95.0 / 100.

Key Facts

  • Structure: Switzerland (CH)
  • Current headquarters: Austria
  • Working profit used for euro tax items: €2,000,000 a year (User-supplied profit_eur)
  • Corporate tax (primary): 11.71% (Zug) → €234,200 a year · Combined effective CIT 2026 (Bund + Kanton + Gemeinde at the Hauptort). Default seat Stadt Zug. KPMG Clarity on Swiss Taxes 2026; PwC-SRF-Steuervergleich 2026. Not a nationwide lump. Switzerland: the stored corporate-tax rate is the canton of Zug (11.71%), the engine default because it is the lowest ordinary rate in the country. Another canton changes the figure substantially — Zurich 19.47% and Bern 20.54%, up to about 1.8× the default, i.e. 8.8 points of working profit on the same company and the same payroll. Communal multipliers move it again inside a canton. Additional cantonal taxes — capital tax, the owner's tax on a dividend, the STAF patent-box relief — are not computed: they depend on the exact company seat, and a canton other than the stored default was not stated. Fix the canton before this figure decides anything.
  • VAT / GST (primary): 8.1% standard rate · PwC WTS Quick Chart VAT rates. Not a euro amount — place-of-supply is not in this ranking.
  • Revenue band: €10–50m
  • Taxable-presence: 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.
  • Visa / permit SLA on file: Switzerland: 56 days (EU–CH AFMP; SEM quotas for non-EU)
  • Knowledge base: 2026-09-18+56080116

Statutory References

Treaty pairs behind this move

PairTreatyArt. 5-style service daysSource
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

  • Austria (2026-01-01): § 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. — § 10a KStG; BDO Austria — Low Taxation Threshold for Anti-Abuse Rules Raised to 15%
  • Switzerland (2026-06-30): 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. — Federal Department of Finance, OECD minimum tax implementation; ESTV Ergänzungssteuer / OMTax; Canton of Zug OECD-Mindestbesteuerung (filing deadline)
  • Austria (2028-01-01): 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. — Budgetbegleitgesetz 2027–2028; KPMG Austria Reporting News August 2026; PwC WTS Austria corporate tax

Instructions to Counsel — open items

Each line is a field this engine does not carry, restated as a work item. Nothing here is an estimate we are withholding.

  1. Give a written permanent-establishment position for Switzerland on the intended setup: where customer contracts are concluded, where day-to-day management sits, and whether any home office is at the disposal of the company. Stored band is medium; this engine does not opine.
  2. Austria — § 10a KStG — Hinzurechnungsbesteuerung (CFC): Switzerland is taxed at 11.71% against Austria's 15% low-tax line. 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? Control test on file: more than 50% of shares, voting rights or profit entitlement, directly or indirectly. Applies to financial years beginning after 31 December 2025.
  3. Austria — § 27 Abs 6 EStG — Wegzugsbesteuerung on privately held shares: deemed disposal of the unrealised gain when Austria loses its taxing right at 27.5%. 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? Reporting on file: annual reporting duty from 1 July 2026 for amounts above EUR 100,000.
  4. Confirm the current treaty text for the 1 pair in this structure, including the Article 5 service-day threshold for the 1 pair where no day-count is stored.
  5. Quote the notary on the actual capital and form. Switzerland: Notary is cantonal and value-scaled. No federal rate. The stored CHF 420 is the federal Handelsregister fee only (HRegV / GebV-HReg).
  6. Confirm the occupational-pension scheme that will actually apply in Switzerland: Already inside the CH plan employer load. Ueberobligatorium excluded..
  7. Identify banks in Switzerland that will onboard this ownership structure as a non-resident applicant. No official onboarding day-count is published; the bank sets the timeline.

Accountant / HR export — granular payroll & tax breakdown

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.

LineSwitzerlandLiechtensteinCyprus
Employee social contributionsAHV/IV/EO 5.3%~€2,544AHV/IV/FAK/VK 4.90%~€2,352~€458
Employer social contributionsAHV/IV/EO 5.3%~€2,544AHV/IV/FAK/VK 7.385%~€3,545~€616
Unemployment employeeALV 1.1% cap CHF 148,200~€528ALV 0.5% cap CHF 126 000~€240Inside the social-contribution line in this model
Unemployment employerALV 1.1%~€528ALV 0.5%~€240Inside the employer social-contribution line in this model
Occupational pensionBVG Pillar 2 estimate · age 45-54, employer share 60%, typical kasse risk; Ueberobligatorium excluded~€3,471kasse-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 taxQuellensteuer ZG A0N 1.51%~€725Landessteuer 1.2% of taxable + Vaduz Zuschlag 150%~€1,362~€470
Municipal / communal multiplierZug 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×

Employer Cost Factor: ~1.14x. For every €1.00 gross salary paid to the employee, budget ~€1.14 in total company costs.

Reference €5,000 seat estimate; the actual factor varies by gross salary, role and contribution caps.

Next Steps: Use this factor for high-level business planning. Forward the detailed calculation basis below to your local tax advisor or Employer of Record (EOR).

🔽 View Expert Details & Calculation Basis

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).

Tax Counsel Advice

Have the payroll provider restate these lines on the actual employment contracts and the actual municipality. Contribution ceilings, communal or cantonal tables and occupational pension terms move the per-head cost, and none of them is settled by a national headline rate. (Switzerland: Kanton Zug Tarif A0N. Liechtenstein: BPVG).

Verify all rates, substance requirements, permanent-establishment positions, and filings against primary law and current administrative practice. The engine does not file, quote or represent you.

Reports are intended solely for informational and business analysis purposes within the framework of IT and management consulting. It explicitly does not constitute tax advice, legal advice, or payroll accounting, and in no way replaces individual consultation by a qualified professional (e.g., tax advisor or attorney-at-law). All analyses, key metrics, and calculations are based on provided data or mathematical models; no liability is assumed for their accuracy, completeness, or timeliness.

Money

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 todaySwitzerlandLiechtensteinCyprus
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-outLiechtenstein €1,165,158/yr ~1.08× company cash-outCyprus €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/yrCyprus 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 PPP63.3% of output · Eurostat D1/GVA 202355.7% of output · Eurostat D1/GVA, SE-imputed 2025
Annual company-maintenance feesnone on the published tariffnone 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.

Payroll at your entered gross (estimate) in Switzerland

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).

ClassGross / monthNet / month Employer SSCCompany cash-outPer €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)

Employer Cost Factor: ~1.14x. For every €1.00 gross salary paid to the employee, budget ~€1.14 in total company costs.

Reference €5,000 seat estimate; the actual factor varies by gross salary, role and contribution caps.

Next Steps: Use this factor for high-level business planning. Forward the detailed calculation basis below to your local tax advisor or Employer of Record (EOR).

🔽 View Expert Details & Calculation Basis

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.

Risk

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.

SwitzerlandLiechtensteinCyprus
Taxable-presence risktypical, same band as Liechtenstein and Cyprustypical, same band as Switzerland and Cyprustypical, 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

This is the complete Corporate dossier

Same engine, same knowledge base. The purchased dossier is this artefact computed on the company you enter — not a longer version of a teaser.

Run it on your own company → Prices Executive dossier

Information and estimate only — not tax or legal advice. Verification by local counsel is part of the process the dossier sets out.