With an emphasis on high value creation rather than volume, the Greater Zurich Area is an ideal Swiss location to centralize and consolidate vital business activities such as international management and headquarters’ functions in a cost-effective way. http://www.greaterzuricharea.ch/

1. Greater Zurich Area AG, May 2013: Corporate Structures 1
Switzerland and the Greater Zurich Area are situated
in the heart of Europe and offer international corpora­
tions and businesses some of the best operating condi­
tions available.
Highly attractive tax structures and liberal labor laws,
plus a greatly qualified and specialized workforce sug­
gest that Switzerland and the Greater Zurich Area are
particularly suited to serve as a central gateway to the
European and global market.
International management and headquarters functions
in the Greater Zurich Area
Which corporate structure is best suited for an expan­
sion and consolidation project in the Greater Zurich
Area depends heavily on individual business models and
strategies.
Following is a compilation of the most common and
most beneficial corporate structures that international
companies have successfully adapted in order to con­
solidate vital corporate functions in the Greater Zurich
Area.
Please note: Swiss regulatory and fiscal authorities
provide highly sophisticated solutions for various
business models. Make sure to contact your personal
consultant at Greater Zurich Area AG for individual
quotes!
Global Management Operations from the Greater Zurich Area –
Sophisticated Solutions for Individual Requirements
The most frequently chosen corporate structures per­
form headquarters and/or management functionalities.
While highly diverse and flexible in order to offer the
best possible solution to a company’s specific business
needs, they are all made possible by one of the highest
quality business environments in the world.
Switzerland and the Greater Zurich Area are setting the
benchmarks in virtually every crucial area such as gen­
eral level of service, corporate and individual taxation,
technological and logistical infrastructure, education,
research, business, culture, labor law and ethics. This is
why business in the Greater Zurich Area is truly thriving.
With an emphasis on high value creation
rather than volume, the Greater Zurich
Area is an ideal Swiss location to centralize
and consolidate vital business activities such
as international management and head­
quarters’ functions in a cost-effective way.

2. Greater Zurich Area AG, May 2013: Corporate Structures 2
Benefits of consolidating management operations
in the Greater Zurich Area
• Central location in the heart of Europe, ideal
gateway to the European marketplace.
• First-rate international connectivity by air, road
and rail.
• Attractive tax environment.
• Multilingual and highly qualified workforce.
• One of the most liberal labor laws in Europe,
ease of doing business.
• Swiss have excellent international management
skills.
• English is an unofficial second language and
standard business idiom in most corporations.
• Great international schools and excellent quality
of life make it easy to attract and retain
international managers.
Corporate structure: Management and Principal
Headquarters
The most attractive corporate structures for internation­
al companies to settling in the Greater Zurich Area are
headquarters.
Establishing regional (EMEA or European) and world­
wide headquarters in the Greater Zurich Area has been
a favorite with international companies ever since
Switzerland’s gilded age. Following Brown Boveri & Cie
(today’s ABB), famous examples included DuPont in
the 1960s, Hewlett-Packard and General Motors in the
1990s. Other arrivals were Kraft Foods in late 2006 and
Ecolab in 2008, among many others. More recently, the
Greater Zurich Area has also seen an uptick in Asian cor­
porate settlements, like Chinese solar companies YINGLI
Green Energy Holding and LDK Solar.
Studies by Arthur D. Little and the Swiss-American
Chamber of Commerce demonstrate the highest satis­
faction among companies who have chosen Switzerland
as their headquarters’ destination. 90% of these compa­
nies would pick Switzerland again.1)
In general, a distinction is made between two main
types of headquarters: the Management Headquarters
and the Principal Headquarters.
Management Headquarters
Description
The main function of a Management Headquar­
ters is to perform business and financial manage­
ment of the group.
In addition to these core functions Management
Headquarters can take on additional functions
and services along the value chain such as human
resources, marketing & sales, IT services as well as
Intellectual Property (IP) development and utili­
zation, patent and trademarks management.
Depending on the group structure, this can be
expanded to a Shared Services Center (SSC).
Advantages/opportunities:
• Management Headquarters enjoy privileged
tax regimes of the Holding or the Mixed
Company, if their business is mainly outside of
Switzerland. With that, effective tax rate var­
ies from 8 to 12%.
• Swiss domiciled headquarters are usually
taxed on a cost-plus basis. Mark-ups of service
companies must be determined in accordance
with the arm’s length principle of the OECD
transfer pricing guidelines.
When shifting tax bases to Switzerland exit taxes
in the source countries may apply.
Principal Headquarters
Description
Principal Headquarters are different from Man­
agement Headquarters in one crucial aspect:
A Principal Headquarters within an international
group assumes risks and responsibilities with re­
spect to the entire supply chain such as develop­
ment, production, procurement, sales market­
ing. Group companies become limited-risk service
providers of the Principal Headquarters.
Consequentially, manufacturing group compa­
nies are converted to contract manufacturers,
sales distribution companies are converted to
commissionaires.
Advantages/opportunities:
• Taxation as a Swiss principal: The overall
income tax burden of a Swiss principal in a
cost-­sharing structure can generally be lim­
ited to 5 to 8%.
When shifting tax bases to Switzerland exit taxes
in the source countries may apply.
1) Foreign Companies in Switzerland; Joint Study by the Swiss-American
Chamber of Commerce and the Boston Consulting Group; Zurich Janu­
ary 2006; Headquarters on the move; Study commissioned by Arthur
D. Little (Schweiz) AG, Zürich 2004, both documents available upon re­
quest. For up-to-date information on multinationals, please visit Swiss
Holdings, Federation of Industrial and Service Groups in Switzerland
(http://www.swissholdings.ch).

3. Greater Zurich Area AG, May 2013: Corporate Structures 3
Business Control Center
A Business Control Center (BCC) is a business model to
centralize regional or worldwide management respon­
sibilities and risks. A BCC is an operative model used to
streamline group processes and to facilitate principal
trading and coordination between all the different enti­
ties of a corporation (manufacturing, sales, distribution,
logistics, marketing finance, RD, etc.). A BCC is often
set up to centralize global Intellectual Property Rights
and Supply Chain Management.
In order for tax privileges to apply, it is recommended
that a Swiss BCC of an international group be set up
as a Swiss principal i.e. responsible for and exposed to
the risk of its service providing companies. These group
companies have a contractual agreement with the
principal company for manufacturing and production,
while sales and distribution are effected on a commis­
sion base.
Benefits
• Applying a BCC business model effectively shifts the
company’s international profits into the Swiss BCC.
• Income tax rate for a BCC in the Greater Zurich
Area is 5 to 8%.
• A Swiss BCC significantly drives the group’s tax rate
down.
• A BCC allows for greater control over operational
business flow.
Shared Services Center
A Shared Services Center (SSC) is an independent entity
that provides support and/or operational services to
multiple business units of a corporation. As a center of
excellence, it is a service provider to its internal custom­
ers according to universal service level agreements,
typically through contractual arrangements.
Activities and services performed by an SSC may include
finance, accounting and IT support, and can extend to
sales marketing support, human resources, supply
chain management and more recently front-office
activities such as call centers.
As mentioned above, an SSC often operates in combina­
tion with a headquarters function.
Benefits
• An SSC enables local operations to concentrate on
their core skills and adapt fast to market changes,
heightening the company’s flexibility during
periods of growth and retraction.
• An SSC improves service level and quality while
consolidating know-how and other crucial company
information.
• By doing so an SSC increases efficiency and reduces
costs.
• If located in a low tax jurisdiction such as the
Greater Zurich Area, tax privileges may apply
(mixed company status on cantonal level and/or
Swiss principal on federal level).
• Effective tax rate may vary from 5 to 12%.
Its multilingual and highly skilled work­
force, as well as its liberal labor laws
allowing e.g. for flexible night and week­
end shifts for 24/7 service and operation,
and its superior infrastructure (e.g. for
IT services), make the Greater Zurich Area
a natural choice and ideal location for a
Shared Services Center.
The Greater Zurich Area offers the complex
and diverse skills required to run a success­
ful BCC. In addition, a BCC in the Greater
Zurich Area is a guarantor for one of
the most advantageous tax optimizations
possible to multinational corporations.

4. Switzerland
Greater Zurich Area AG
Limmatquai 122
8001 Zürich / Switzerland
Phone +41 44 254 59 59
Fax +41 44 254 59 54
info@greaterzuricharea.ch
www.greaterzuricharea.ch
USA
Greater Zurich Area Inc.
swissnex building
730 Montgomery Street
San Francisco, CA 94111 / USA
Phone +1 415 912 5909
CHINA
Jianping Gao
Representative China
Phone +86 21 6149 8208
Have we sparked your interest?
Would you like to get to know your options in the
Greater Zurich Area in more detail?
If yes, please contact your nearest Greater Zurich
Area representative for more information.
We are happy to assist you in every aspect of
expanding your business to the Greater Zurich
Area!
The Greater Zurich Area is an ideal location to set
up a highly effective, successful and cost-efficient
corporate structure with central management
functions.
Realizing these business models in the Greater
Zurich Area guarantees international corporations
to tax-efficiently manage commercial operations in
the European or global market under privileged tax
regimes.
Please note: Specific conditions (e.g. special legal
or fiscal constraints, and exit taxes) may apply
depending on the country of origin of a company.
We strongly recommend discussing your project
with specialists from the Greater Zurich Area AG
and their fiscal, legal and administrative affiliates.
This will help you to optimize, harmonize and
fine-tune the many different aspects involved in
a relocation or expansion project to the Greater
Zurich Area.
Greater Zurich Area AG, May 2013: Corporate Structures 4