Business and wealth between Croatia and Switzerland: where Switzerland offers real advantages

What Switzerland offers

Anyone who has built a successful business in Croatia sooner or later asks how to give the business and their wealth a broader base. Switzerland is an obvious partner for this, often for different reasons than one might first think. Five areas stand out:

1. Wealth management: access to Swiss banks and independent asset managers, accounts and custody accounts in several currencies and a wide choice of investments.
2. Corporate structures: a Swiss AG or GmbH as an operating company, an investment company or a holding company above several companies.
3. Location and reputation: a Swiss registered office builds trust with international customers, partners and investors.
4. Asset protection and succession: clear legal forms, wealth spread across several countries and long-term planning for the family.
5. Tax in certain cases: for example on profits actually earned in Switzerland, on participation income of a holding company or on a genuine change of residence.

Business owners whose business or wealth already has an international dimension benefit most: companies with customers abroad, groups with several companies, families facing succession or the sale of a business.

A Swiss company with real activity

An example: a Croatian IT or trading company earns a profit of EUR 500,000 on revenue of EUR 3 million. If it moves a substantial part of its activity to Switzerland, the profit earned there is taxed in Switzerland. In the city of Lucerne, the total profit tax burden is around 12 percent.

Example

Profit tax on a profit of EUR 500,000

Croatia, 18 percent90,000

City of Lucerne, around 12 percent60,000

Simplified calculation in the same currency, without taxes on distributions and without the costs of the structure. In Croatia, the 18 percent rate applies from revenue of EUR 1 million.

The difference is real, but only if the profits genuinely belong to Switzerland in economic terms. What counts is where the company is actually managed and where value is created. If management, employees and operations remain in Croatia, Croatia may continue to tax the profits, even if the company is registered in Switzerland.

Holds up

• Management decides in Switzerland
• Employees, office and customers in Switzerland
• Contracts and invoices run through the Swiss company
• Proper charging of services with the Croatian company

Substance⇄

Does not hold up

• Only an address and a commercial register entry
• Decisions are still taken in Croatia
• No employees of its own in Switzerland
• Profits shifted without a link to the activity

Clear rules apply to formation: an AG needs share capital of at least CHF 100,000, of which at least CHF 50,000 must be paid in at formation. A GmbH needs CHF 20,000 of capital, fully paid in. In both cases, a person resident in Switzerland must be able to represent the company.

The Swiss holding company

For business owners with several companies, a Swiss holding company can form the roof of the group. It holds the participations centrally, finances subsidiaries, can take on investors and makes a later succession or sale easier.

For tax purposes, Swiss law provides the participation deduction: dividends from participations of at least 10 percent or with a market value of at least CHF 1 million, as well as gains on the sale of participations of at least 10 percent held for at least one year, are largely relieved from profit tax at the level of the holding company.

The interplay between both countries is decisive. Croatia also grants relief for participation income, and dividends from Croatia to a Swiss company may be subject to withholding tax, which the double taxation agreement limits. A holding company usually brings the greatest benefit when it is more than a tax model: when it brings together expansion, financing, management of the group and succession.

Investing wealth in Switzerland without moving

Many business owners do not want to emigrate but would like to spread part of their wealth internationally. Switzerland offers banks with long experience in international business, independent asset managers, custody accounts in several currencies and solutions for succession.

• Securities remain yours: shares and fund units in a custody account belong to the client. If a bank goes bankrupt, they are segregated and do not form part of the bankruptcy estate.
• Deposits are protected: account balances are protected by deposit insurance up to CHF 100,000 per client and bank.
• Transparency towards Croatia: a Swiss account does not change your tax liability. If you live in Croatia, you pay tax on the income there. Switzerland exchanges account data with Croatia under the automatic exchange of information.

The bank and asset manager are responsible for the investments themselves. I make sure that overviews, tax documents and the coordination between both countries are correct.

Moving your residence to Switzerland

Since 2026, quotas no longer apply to Croatian nationals. Even those who do not work in Switzerland receive a residence permit if they have sufficient financial means and health and accident insurance.

When you move, you become liable to tax in Switzerland on your worldwide income and wealth. Gains on the sale of securities held as private assets are generally tax-free in Switzerland. For wealthy persons without Swiss citizenship who move to Switzerland for the first time or after at least ten years and do not work here, there is also taxation based on expenditure. The canton of Lucerne offers it.

Anyone who continues to run their Croatian company from Switzerland after the move will generally not meet the conditions for it. In addition, the Croatian company may then become liable to tax in Switzerland if it is managed from here. More on this in the article Moving to Switzerland as a business owner.

The double taxation agreement

Switzerland and Croatia have had a double taxation agreement since 1999. It determines which country may tax profits, dividends, interest and salaries. An amending protocol adds an anti-abuse provision and exchange of information in line with the international standard. The Swiss Parliament approved it in June 2026. It enters into force once both countries have completed their procedures. The current status should be checked before any specific structure is implemented.

The questions to clarify first

1. Which goal comes first: growth, financing, asset protection, succession or a move?
2. Which activity will actually take place in Switzerland in future, and who decides where?
3. Which profits belong to the Swiss company in economic terms, and how are services between the companies charged?
4. Which taxes arise on distributions, in Switzerland and in Croatia?
5. Who represents the Swiss company, and who handles accounting, VAT and year-end closing here?
6. How do your adviser in Croatia and your adviser in Switzerland coordinate?

A structure that holds in both countries

A connection between Croatia and Switzerland is worthwhile when it makes economic sense and stands up in both countries. Anyone who relies only on a lower tax rate risks back taxes. Anyone who uses Switzerland as a location for business, wealth and family creates a structure that lasts for years.

I advise in German, English and Croatian, know Swiss company and tax law and work directly with your adviser in Croatia. That way, both sides fit together from the start.

This article provides a general overview and does not replace advice in individual cases. Your adviser in Croatia is responsible for Croatian law and Croatian taxes. As of November 2026.