At first I've been told that it's definitely possible. I've written another email to the advisor to make it clear that we're talking about leveraged trading on a daily basis. My primary concerns are that my company may be liable to the Swiss corporate taxes but my suggestion was that it could be avoided by using an LLC instead of an LTD therefore only I would have to pay the taxes and not the company itself and I would be a lump-sum taxpayer so it could work. The other concern is that the authorities may say that it's Swiss sourced income thus subject to the regular rates. I hope that this type of activity through an LLC will qualify as managing your personal assets. In that case the minimum tax payable would be around $150k per year but it's different in each Canton.
Changes from 2016 onwards The revised law on taxation on expenses will enter into force on 1 January 2016, which will increase the minimum requirements. After this date, the minimum requirements will increase at both federal and cantonal levels: income tax will then be calculated on seven times the annual rent paid (or imputed rental value). In addition, at federal level, a minimum threshold of CHF 400,000 will apply. The cantons are required to define a minimum threshold as well, however they may define it at their own discretion. What should be done? Especially if the living expenses lie below the new limit of CHF 400,000, persons taxed on expenses should reassess their situation.
@i am nobody : I know, the min. tax base in most Cantons is CHF 400,000. For instance in Zug the total tax payable, including federal, cantonal and communal taxes plus the wealth taxes would be CHF 165,495. http://www.kpmg.com/CH/en/Library/A...nts/Tax/pub-20150708-lump-sum-taxation-en.pdf But the question is not this. The question is what I've mentioned above. Does it qualify as managing my personal assets or not?
Do swiss authorities need to know how you derive your income exactly, as you won't have to fill tax returns afaik ? If you use an offshore structure do you need to disclose the exact details of this company ? I checked a while ago btw for Geneva and from memory with the new calculations the payable tax under the lump sum scheme will be much more than 86k chf,(but Zug is probably cheaper, I trust you have done your homework ). Cost of living is also noticeably higher than in neighbouring countries. I suspect you would make saving by declaring enough to justify your expenses and paying taxes on this while keeping the remaining of your income offshore without much hassle in several European countries (particulary southern). That's not to say quality of life in Switzerland is not worth some extra bucks, but you seem to be willing to settle anywhere - but then again if you are afraid that UAE or similar authorities would disclose your personal and corporate accounts in their country to the tax authorities of your country of residence on an automatic basis, disregard the above.
@Hittfeld : I'm talking about the lump-sum tax agreement whereby you pay a fixed amount of tax each year determined by the Cantonal authorities. Let me know if you want to know how they calculate your tax base. @luisHK : As far as I know you have to tell them the source and nature of your income at the time you want to make an agreement with them. The correct amount is ~165k in Zug, sorry for the mistake. I share a different opinion on this. Switzerland is clean, safe and stable. I would live there if I could qualify for the lump-sum taxation. If I qualify then I don't really care whether a certain country share my account information with Switzerland or not since I only pay a fixed amount of tax each year. This is the reason why I'm looking for a perfectly legal solution, I do not want to be worried about this.
I'm not sure if you were addressing me, but I share the same opinion about Switzerland, I actually like the country very much, although with the EURCHF at 1.03 I prefer travelling in the Eurozone at the moment (will be in Geneva next week though, relaxing for a couple of days)
dw31583 My warning regarding US taxation is not a joke. Regarding your original question: There is a case just to be decided. If I recall this correctly, its one of the russian oligarchs residing in or near Zurich (could be Zug). This guy is running an office in Zurich - managing the world wide engagements of his holding.
Is it difficult to stress another activity in the company you trade with ( for instance I have 2 professional activities, one which resists pretty well to the the territorial taxation issues ) ? Do swiss authorities ask audited statements (I suspect they do but not sure)?
I heard about estate tax issues with US brokerages but thought it was settled, is it also a risk for non swiss residents ? Also it should apply only to personal accounts, not corporate, for corporate accounts the probate is also complicated but the heirs need to deal with the company's country of registration authorities. Would you agree to the last part ?
dw31583 This should give you some more information on your original question: http://www.tagesanzeiger.ch/schweiz/standard/Der-Fluch-des-Steuerwettbewerbs/story/28195243 [/QUOTE]