Swiss holding structures remain legitimate in 2026, but the era of the “holding company as a mailbox” is over. The pressure is coming from two directions at once: global minimum tax rules (Pillar Two) and a substance-first approach to transfer pricing and group governance. If the structure does not align with the business's actual operations, it will struggle under audit, and it will almost always struggle in due diligence.
Why scrutiny is rising now (and why 2026 feels different)
Two changes reshaped the baseline.