Of course we need to distinguish between the corporate tax version and the transparent one. In that case we talk about the corporate tax version aka SCI à l’IS.
- The SCI is taxed on its fiscal revenue at 15% up to 38k ish and 30% ish above (getting lower) and indeed not taxed in CH
- Interests are deductible from the SCI revenue as any fees (e.g. accounting, depreciations, etc.)
- To be fair I don’t know in that case but they usually apply the practitioner method (https://www.businessbroker.ch/en/business-value/valuation-methods). In that case though the guy told me that if the company holds real estate it should not be taxed at all in CH since it can be taxed in France for the wealth part (called IFI). I will declare it in the security section and I’ll let them correct it as required I guess.
- You are taxed on dividend distributions and if you own 10% of the shares you benefit from a reduced tax rate (depend on the canton though)
Owning real estate in France directly exposes you to a 27.5% tax rate below 20k of revenue and increases your overall tax rate in CH as you are taxed on your global revenues. There’s also an impact on deduction that are apportioned based on the location of your wealth. One of the drawback of the SCI is the liquidation that will cost you a lot more compared to owning the real estate directly.
Everyone needs to make calculations to know what scheme fits his goal best ^^.