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Hey there, I am in the process of relocating to Switzerland and my tax advisor suggested me to get organized before moving in. In particular suggested me to setup a company (ideally before entering Switzerland and outside of Switzerland) and fund it with debt. The idea is the following: if I...

No, under this scheme you only pay IT source income, so in other words CFC rules do not apply. Plus, there has been a recent ruling that calls crypto foreign currency for the purpose of flat tax, so as long as you do not explicitly custody it in an Italian exchange you are fine.

interested to follow up. Any reason you looked into RAIF instead of an SLP?

Lol, that's way different than us estate tax!

Corporate tax is the local rate, but it will be exempt since it's a securitization vehicle

The Securitization vehicle seems way more interesting.. it give you 0 tax while trading, differently from the SCSp which depending on where you are it might be transparent. There is an issue with the securitization vehicle though, whatever you securitize must have single strategy.. what are you...

Doesnt the US solution give you Estate tax issues at your death?

If you run it as a total legit fund in EU, you end up only paying gains once you sell your position in the fund.

Why would you need the LLC? Can you not just do LTD?

can you tell us more about the sarl option you mentioned?

Can you give me some examples?

It shouldn't be hard to set up a small company with friends and hire you though..

What about those that can't benefit from that program?

What would be alternative options you have in mind?