We have a Swiss client with an island that is privately owned in Sweden and the plan to build a resort on the island.
We need tax and legal advice in the following areas.

1. Do we need to transfer the island into the company, or does it make sense to have the island privately and found a company that just owns the building and the operation on the island? If the island is transferred into the company what is the tax and which market value do the authorities take for the island ( purchase price)

2. Possible Scenarios
a) Construction of little resort- sale of the complete little resort including island
Capital gains tax (if island is company owned, if the island is privately owned), what are the different rates? How high is capital gains tax? Anything to pay attention to? Is it important how long we own the island (in Switzerland for example the years of ownership change the rate).
b) Construction of little resort- leasing it out- yearly rental income
A - What is the income tax for a company?
B - Different company structures and different tax rates? Same tax rate for everyone?
C - Depreciation of construction costs/building- how many years?
D - Are interest payments deductible?
E - What is the Property tax rate?

3. VAT tax. Can we apply for VAT from the beginning and deduct it for all payments? When will the VAT be paid back? Only when we have income or already upfront? Anything to consider here?

4. Is there any withholding tax or anything to consider for dividend payments from this company, as we are Swiss and non-EU residents?

5. How long can you use an accounting loss in the early years for the deduction from future gains (indefinite, or limited?)

6. General questions: Costs for founding a company, setting up VAT for this company and yearly accounting fee during construction.

We’re looking forward to hearing from you.