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Switzerland-US Tax Treaty for Wyoming LLC Owners

Swiss residents running Wyoming LLCs benefit from a strong US tax treaty. Article 7 protects business profits. Dividend rates drop to 5-15%. Royalties drop to 0%. Here is the breakdown.

Answer

The Switzerland-US tax treaty is active. Dividends drop to 5% for 10%+ ownership, 15% otherwise. Royalties drop to 0% under the treaty. Article 7 protects business profits from US tax. The Swiss Federal Tax Administration generally recognizes US LLC pass-through. For Swiss founders running operating businesses, US federal income tax is typically zero on revenue.

By Zawwad, Founder & CEO, WyomingLLC by Topslice LLC.

Last updated May 20, 2026

Treaty rates

  • Dividends: 5% for 10%+ ownership, 15% standard
  • Royalties: 0% under the treaty
  • Interest: 0% on most types
  • Business profits (Article 7): protected from US tax

Swiss tax treatment of US LLC

The Federal Tax Administration (FTA) generally treats US LLCs as transparent for Swiss tax purposes. Pass-through income flows to your Swiss tax return. Cantonal tax rates apply on top of federal. Consult a Swiss Treuhänder (tax/finance advisor) for canton-specific treatment.

When Swiss founders form Wyoming LLCs

Common cases: SaaS founders targeting US customers, agencies serving US clients, content creators with US-source revenue (YouTube, Patreon). Swiss residents are typically high-income earners, so the tax efficiency of pass-through LLC pairs well with treaty rates.

Form 5472 mandatory annually

Form 5472 + pro forma 1120 filing required regardless of treaty status. $25K penalty for non-filing. Apply through $WyomingLLC's $99/year add-on or file independently.

Frequently asked questions

How is the Swiss tax treaty different from EU treaties?
Switzerland is not EU. Bilateral US-Swiss treaty. Generally generous like Netherlands or Germany. Royalty rate at 0% is among the most generous globally.
Can I run a Swiss GmbH and Wyoming LLC together?
Yes. Common pattern for Swiss founders. GmbH for local Swiss ops, Wyoming LLC for US-facing.
Wealth tax in Switzerland on LLC?
Cantonal wealth tax may apply on the LLC equity value. Consult a Swiss Treuhänder for canton-specific treatment.

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