The five candidates

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Swiss law offers a digital-asset venture five vehicles that are used in practice: the company limited by shares (Aktiengesellschaft, AG), the limited liability company (Gesellschaft mit beschränkter Haftung, GmbH), the foundation (Stiftung), the association (Verein) and the registered branch of a foreign company. Each answers a different question. The AG and GmbH are operating and holding vehicles for a business that expects to earn profit and to be owned. The foundation is a vehicle for assets dedicated to a purpose without owners, which is why it has become the standard home for protocol treasuries. The association is the natural wrapper for a membership organisation, which is why it is used for DAOs that want a legal person without giving up member governance. The branch is the thin option for a Singapore or other foreign company that needs a Swiss presence without a Swiss subsidiary.

The choice is rarely one of the five. The pattern I see most often in Zug combines an operating GmbH or AG, a foundation holding the protocol treasury and a Singapore operating company for the Asian market. This chapter takes each vehicle in turn and then explains that pattern. Part C, Chapter III, describes the Zug ecosystem in which these entities sit. Part D, Chapter III, covers the tokenisation of the AG's shares as ledger-based securities.

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.

All Singapore law advice is provided through KGP Legal LLC, an established and duly licensed firm of Singapore advocates and solicitors.

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.

If you are planning a company incorporation, an investment, a holding structure or a market entry through Singapore, you can reach Dr Ressos directly at [email protected]. Singapore law advice is provided by KGP Legal LLC, a licensed firm of Singapore advocates and solicitors. Dr Ressos and his team facilitate the full range of Singapore legal, compliance and company administration services, including company incorporation, corporate transactions, commercial contracts, crypto and digital assets, financial regulatory work and dispute resolution, including litigation in the Singapore courts. For Hong Kong, our parallel site HongkongIQ.com offers the same practical guidance. For crypto and digital assets, dltreg.com covers legal, tax and fiduciary services. For legal, tax and fiduciary services in Switzerland, see helveticaregister.com.