Comparative view: the Swiss vehicles against their Singapore counterparts

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The reader who has read Chapter III will see that each Swiss vehicle has a Singapore analogue of similar shape and different texture. The AG corresponds to the private company limited by shares and the foundation to the company limited by guarantee. The association has no close counterpart apart from the registered society, while the branch has its Singapore twin in the registered foreign company. The decisive differences are two. Swiss foundations are supervised by a state authority that reviews purpose and governance, whereas a Singapore CLG is a company with members and no external supervisor beyond ACRA's filing regime. The Swiss foundation therefore offers stronger assurance to a community but less flexibility to a founder. Swiss company law publishes the members of a GmbH and requires a resident representative. Singapore requires a resident director and publishes the directors and shareholders of every company. Neither hub offers anonymity of ownership at the entity level.

Function	Swiss vehicle	Singapore vehicle (Chapter III)
Operating business, owned and saleable	AG or GmbH	Private company limited by shares
Protocol treasury without owners	Foundation (Art. 80 ff. CC)	Company limited by guarantee
Member-governed DAO	Association (Art. 60 ff. CC)	Society or CLG with member voting
Fund vehicle	L-QIF, SICAV, LPCI (Chapter VI)	VCC (Chapter VI)
Local presence of a foreign company	Branch (Art. 952 CO)	Registered foreign company (Part 11 Companies Act)
External supervisor of governance	Supervisory authority for foundations	None (ACRA filings only)
Publicity of owners	GmbH members public; AG shareholders not	Shareholders and directors public

For general information only. This article does not constitute legal or tax advice, does not replace advice on an individual case and creates no lawyer-client relationship. It reflects the legal position as of October 2026.

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Dr Alexander Ressos, TEP

Of Counsel, KGP Legal LLC

I am Of Counsel with KGP Legal LLC in Singapore, where I work with a global client base of successful entrepreneurs and their families, independent asset managers, commodity trading houses and other commercial clients. I am a German and Swiss attorney-at-law, also admitted as a solicitor in England & Wales and in Hong Kong. I divide my time between Zug in Switzerland, Singapore and Hong Kong. Since 2017 I have advised international clients on more than 700 crypto and digital asset projects. I also have extensive experience in cross-border litigation and arbitration in Singapore, Hong Kong and other markets in South-East Asia and Greater China.

I operate across the key financial centres in South-East Asia, the Middle East and Switzerland, with a particular focus on asset protection, international tax and estate planning, as well as trusts, company administration and other fiduciary services. My philosophy is to serve as a trusted advisor working closely with my clients and to help them achieve their commercial objectives.

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KGP Legal LLC is a medium-sized law firm in Singapore that is capable of providing the full range of legal services and corporate administration work. Please contact me if you need any further information.

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SingaporeIQ is edited by Dr Alexander Ressos, an international business lawyer with more than 15 years of local experience in Singapore as a permanent resident, a Singapore registered foreign lawyer and managing partner of a Singapore foreign law practice. In addition to significant experience in cross-border investments and transactions, UHNWI private client work and sanctions/export controls, Dr Ressos has extensive experience in cross-border business and in crypto and digital-asset projects in Singapore, drawn from more than 700 projects since 2017.

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