Case study: Switzerland
Shell has a significant presence in Switzerland and we employ around 120 people there. We have located supporting services there that are important to our businesses, including financing, insurance and trademark management operations. Three hundred Shell-branded retail sites serve around 80,000 customers every day. We also have a lubricants blending plant.
Switzerland is a country whose tax regime has been the subject of public scrutiny. Switzerland has recently approved new tax rules that result in a combined regional and federal tax rate of 12% from 2020. The tax reform replaces certain preferential tax regimes with a new set of internationally accepted measures.
Here we provide more information about the service activities performed in Switzerland and the essential role they have played in supporting our business activities.
Shell is exposed to material risks which are predominantly insured by one of our entities in Switzerland. We maintain sufficient capital and reserves in the event of a claim and we employ professionals with finance and specialist insurance expertise, including in-house actuarial expertise. Shell’s insurance operation is licensed and regulated by the Swiss Financial Market Supervisory Authority (FINMA).
Shell has a number of trademarks used by both Shell companies and third parties including those that own and operate some of our retail sites. Most Shell trademarks are owned by Shell Brands International AG (SBI), which is based in Switzerland.
SBI owns, licenses, enhances and protects the value of Shell trademarks. SBI receives royalty payments from Shell operating companies and third-party licencees. Revenues from third-party licencees account for around 50% of the total trademark royalty revenues.
Shell companies pay royalties for the use of the trademarks in the same way as third parties. This is in line with international transfer pricing standards as defined by the OECD.
Our trademarks are registered with the relevant government agencies in many jurisdictions. SBI owns and manages a portfolio of more than 15,000 registered trademarks.
Shell issues bonds in the financial markets to raise funds. Some of these funds are used by a company registered in Switzerland to finance some of our operating companies. Loans are provided on arm's-length terms, which means that the interest rate charged is the same as if it had been provided by a bank. This is required under international transfer pricing rules which all companies, including Shell, must follow.
From 2020 onwards, we will no longer provide these financing operations out of Switzerland. They will be provided from one of our existing treasury service locations.
International groups like ours are exposed to movements in the value of different currencies as part of our normal business operations. Sometimes these currency movements create gains and sometimes losses. In 2018, the changing value of different currencies resulted in a loss.
Shell has hedging activities in Switzerland to reduce our exposure to these currency movements. From the end of 2019, we are substantially reducing these activities in Switzerland.