Before tax planning
Under US tax law, companies pay a 35% corporate income tax rate on profits they earn around the world but on profits earned outside the country, they don't have to pay US taxes unless they are repatriated. This therefore acts as an incentive to book profits in other jurisdictions and leave them there (this is often referred to as the lock-out effect). In this regard, Switzerland became the country of choice, inspired by a negotiated tax rate of 4% and the availability of appropriate personnel.