There is a tax liability for legal persons when the headquarters or the actual administration is in Switzerland (Art. 50 DBG). At the federal level, there is only a tax on profits. Capital tax is not provided for.
The tax liability begins with the foundation or opening (move) of the actual administration to Switzerland or with the acquisition of assets with taxable values in Switzerland. Tax liability ends with the completion of liquidation, relocation of the headquarters or the actual administration abroad and the elimination of assets with taxable values in Switzerland (Art. 54 DBG).
For federal tax purposes, legal persons / entities are divided into two distinct groups. The first group includes capital companies (public company, limited liability company, limited partnerships) and the second includes associations, foundations and the other legal entities (Art. 49 DBG).
Associations, foundations, public sector and religious bodies (churches) pay - if they are not exempt from tax due to charitable purpose - a tax on earnings or income tax at a tax rate of 4.25%.
Cantonal and municipal taxes
With regard to the place where the legal person / entity must pay their taxes, please refer to the execution of the direct federal tax. Here, the seat of the actual administration is the decisive criterion. An economic relation may possibly also be considered.
The vast majority of cantons provide for a tax on net profits, as well as the deposited share capital and the reserves thereof. This applies to public companies and cooperatives.
Depending on the canton, a progressive, a proportional or a mixed tax rate is provided.