PE rules for Swiss or US Corporation

[Marzio]

Why do you think in the DTA between CH and HU they differentiated⁤ between a place of management and a branch?

Because you can have a place of management without a︁ branch so a PE could be created even without registering a branch.

Also it's in︂ OP best interest to create a PE in Hungary because HU levies 9% taxes instead︃ of ~12% (depending in which canton the company is formed) in CH.

DTA only applies to dividends, interest and royalties.

 

[JohnLocke]

Totally agree. If the Swiss company is managed in⁤ Switzerland you will only pay corporate tax in Switzerland and not anywhere else.

Be sure⁣ to structure the company correct to avoid any troubles. Substance i.e. real office etc and⁢ Management must be in Switzerland.

 

[miketrnd]

Interesting. I was under the impression the requirement was more like a local nominee director.‌

That's from one of the service⁤ providers