The investment organization consists of the management company in Zug, Switzerland, the financing companies in Guernsey, and the target companies in Georgia or in Switzerland.
Guernsey was chosen for legal and not for tax reasons. (Limited companies in Guernsey may have different share classes with different voting rights, which is important to finance a non-listed target company.)
The Guernsey-based finance company underlies the Guernsey tax rate (0%) and Swiss Federal and cantonal taxes on profits, capital and distributions. The company benefits from participation exemption in Switzerland.
Investors have to be identified by Swiss GeoCapital AG.