Mixed contribution (Switzerland)

A mixed contribution (apport mixte) is a Swiss restructuring technique combining a contribution in kind (assets transferred to a company) with a partial cash payment by the company to the contributor, resulting in a net contribution rather than a pure asset transfer. It allows entrepreneurs to partially monetise assets while contributing them to a holding or operating company, provided the conditions for tax neutrality under Swiss law are met — particularly the 20% minimum retention threshold and the 5-year lock-up period. In financial structuring, mixed contributions are used to optimise the tax efficiency of business reorganisations while extracting partial liquidity.

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Example: an entrepreneur contributes a business worth CHF 8.0 million to a new holding company. Under a mixed contribution, the holding pays CHF 2.0 million cash to the entrepreneur (partial monetisation) and issues shares worth CHF 6.0 million. Provided Swiss tax neutrality conditions are satisfied, the CHF 6.0 million in shares is tax-deferred — and the CHF 2.0 million cash payment is analysed for its own tax consequences.

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Hectelion advises on mixed contribution structuring and valuation in Swiss corporate reorganisations, coordinating with cantonal tax advisors to confirm neutrality conditions.