Unlimited tax liability

Unlimited tax liability arises where a person or entity has a sufficient personal connection to a tax jurisdiction, such as residence or domicile for individuals, or seat or effective management for companies. In Switzerland it generally means taxation on worldwide income and, where applicable, assets or capital, subject to exclusions and treaty relief. Foreign real estate, permanent establishments or business operations may be allocated abroad under domestic rules or double tax treaties. Establishing or ending unlimited liability requires careful analysis of facts, timing and cantonal practice.