A foreign investor is allowed to invest into Swiss real estate property directly or through a local or a non-resident company if such property is used for permanent business purposes. Restrictions apply for Swiss residential properties.
Real estate funds in Switzerland are often structured in the form of a FCP (contractual fund) as well as in the form of a SICAV (investment companies with variable capital). Both forms need to be approved by the Swiss Financial Market Supervisory Authority FINMA. Both investment fund structures can be listed at SIX (Swiss stock exchange) and can be used for direct or indirect real estate investments. Neither a FCP nor a SICAV is in principle subject to Swiss income tax. However, if the fund invests directly into real estate, the net real estate income is taxed at the level of the FCP or SICAV. Distributions of a Swiss fund are in principle subject to 35% Swiss withholding taxes (WHT). However, for Swiss funds with direct investments in Swiss real estate no Swiss WHT applies on distributions of real estate income.
Source : PWC