(1) If I am to set up a Swiss Company (SA) with share capital of CHF100,000; can all the shareholders be Non Swiss in Nationality and Non Resident in Switzerland?

(2) If I then open a company bank account and put CHF1,000,000 in it and the company actually does not trade as such; will the company not pay any taxes (wealth/capital tax) as basically it has no net assets other than the cash for the share capital. The interest received will be cancelled out by fees so there will be no profit.

BALANCE SHEET

Current Assets
Cash in Hand 1,100,000

Current Liabilities
Loan 1,000,000
_______
Net Assets 100,000
======


Share Capital 100,000
=======

Depends how you structure the CHF 1M "put".
Is it a loan from the shareholders? Then the company must identify and pay the specified interest to the shareholders.

The proposed unusual constellation can provoke the tax office to interpret the amount as:
1. Deemed capital to be taxed at company wealth tax rates.
2. Deemed income for unknown activities.
3. Banking services (requires a license).
4. Attempted money laundering and tax evasion.

Questions will be asked. You certainly need a good story.

Thanks for that but that is not what I wanted to hear.

1. Deemed Capital would be the CHF100,000 Share Capital Net Assets?
2. If there is no income/activities, how can you deem it?
3. Surely opening a bank account and depositing a lump of cash doesn't require a licence? Well wierd!
4. The lump/loan of CHF1,000,000 would appear to be from non EEC country individual investors (say Russia). I am really surprised that the Swiss Tax Office would be bothered?

Pesky details like money laundering and all that.

You seem to know the answers. So why do you ask?

Your company is collecting money from investors and reinvesting it? Then it is either a Bank or a Mutual Fund. Separate legislation regulates such activity.

That mega juicy 1M parked in your company will make the Swiss tax officer salivate and want to take a bite

No, I don't know, that is the problem.

I was looking at ways without trusts etc etc. of keeping money in a bank account accessible by others if real owner of money dies. I was also thinking that it would be a method of avoiding wealth tax on individuals that might be implemented in other countries such as UK at a later date (I am thinking wealth tax in EEC could be implemented in the future) to get some tax as companies/businesses are not making profit and the government wants to stimulate spending.

I am starting to think Switzerland is not as friendly or useful as a place for keeping money/assets as I thought.

You need a tax advisor. They do this sort of thing in Canton Zug all
the time.

Cheers for that, but my clients are not prepared to pay astronomical fees for daft trust schemes that the government changes and become useless/invalid two years later and are not at that league, we are talking about only CHF1,000,000 not CHF Millions.

From what I am reading and the UBS and Swiss government even prepared to disclose information I am better off doing it the dodgy way for my clients which is safer, easier and cheaper than all these schemes.
I was hoping to be able to form Swiss companies (having British and Swiss Nationality), act as director/administartor with the objective of the clients keeping their money hidden except to their family.

Switzerland very strict on money laundering. Beneficial owner must be revealed.

Lets face it Terrorism is the excuse for all the Money Laundering regulations when we all know it has nothing to do with terrorism but the Government/Inland Revenue sticking their big beak into our personal affairs.
Having done a bit of reading over the last few days as I lie here with the flue it appears to me that the UK is the esiest way to launder/hide money from the beneficial owner.
I am a bit disappointed with Switzerland as I was always under the impression that it would not disclose peoples money/financial interest to others including governments and thought the 35% tad dedcution on interest scheme was really good (espeially now interest is hardly any point thinking about for the next 5 years I would guess).

"astronomical fees"? Do you want to set up a trust on the moon?

I often read that on this forum and I am a bit surprised... you are the client, so if you instruct clearly what you want and define a budget, no reason for paying "astronomical" fees... If you go to an advisor and ask him: "tell me what I can do with that", he will probably spend hours and hours on it as there are hundreds of possibilities to structure a business. But in your case, it seems that you know pretty much what you want, therefore your questions are very clear and on specific details you want to know. Therefore how could fees be "astronomical"? Except if you go to a Big 4 office or to a "flashy star tax attorney" (as there are some in CH, not at all at the level they pretend to be...), I don't see how you could end up with significant fees.

You know better than any one else how you want to run your business and how you want to manage your risks, but if I had a Russian client basically lending me CHF 1 Mio, I would prefer covering my a** with a written external advice and put this forward to my client rather than telling him "Trust me it works" and have him knocking at my door with 5 friends late at night once everything went wrong Dont' take me wrong, I'm joking, but sometime it's better to spend some CHF in external advice, nobody can sort out everything by himself, especially over the internet.