The optimum solution can be found by combining:

  • Real estate ownership in Switzerland
  • Domicile in a country which in the DTA5
    • accounts for capital gains from the sale of real estate companies at the domicile of the seller of the interest and not at the location of the real estate;
    • exempts foreign profits or income from the destination country from taxation or taxes at a lower rate.
  • Alternative: A real estate company that qualifies as an operating company.

5 Drawn up in accordance with the old OECD Model Convention.

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