Switzerland

A company is considered resident in Switzerland if its domicile is in Switzerland. Residency is also linked to the place of effective management, which may be the place from which day-to-day activities are directed and/or the place from which managerial decisions are taken.

Permanent establishment (PE)

For Swiss tax law purposes, the term 'permanent establishment' means a fixed place of business through which the business activity of an enterprise is wholly or partly carried on. In particular, PEs are branches, factories, workshops, sales agencies, permanent representations, mines and other places of extraction of natural resources, as well as building or construction sites that are maintained for at least 12 months. This definition is generally in line with the criteria according to the current Article 5 paragraph 2 of the OECD Model Tax Convention on Income and Capital.