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.
