Switzerland: Offshore Legal and Tax Regimes

Taxation of Foreign Employees of Tax-Privileged Operations

There are no special rules applying to the foreign or Swiss employees of tax-privileged operations. The various exemptions from income tax described above do not apply to employees: any business employing and paying people in Switzerland will have to follow the normal rules for the taxation of individuals.

See Domestic Personal Taxation for the general principles of individual taxation of individuals in Switzerland.

A person is deemed resident in Switzerland if:

• They have Swiss employment (to work in Switzerland a non-national needs a work permit - limited work permits of 90-120 days can be granted and where granted lead to limited taxation);
• They carry on a business in Switzerland; or
• They live in Switzerland for not less 180 days in any one year. If however they remain in the same abode, the time required to be a resident for tax purposes drops to 90 days.

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