Residence in SwitzerlandOverview
Expenditure-based taxation allows foreign nationals who take up Swiss tax residence for the first time, or after at least ten years abroad, and who do not work in Switzerland, to be taxed on their annual worldwide living expenses instead of their income and wealth. The taxable base must be at least the higher of a fixed federal minimum — CHF 434,700 for 2025 and CHF 435,000 for 2026 — and seven times the annual rent or rental value of the Swiss home. A control calculation ensures the tax is not lower than ordinary tax on Swiss-source income and certain foreign income for which treaty relief is claimed. Married couples both need to meet the conditions, and Swiss nationals, including dual nationals, are excluded.
Cantons apply the federal framework but set their own minimum bases and wealth-tax add-ons. According to the Federal Tax Administration's 2025 overview, fixed cantonal floors range from CHF 200,000 in Jura and CHF 250,000 in Fribourg and Valais to CHF 600,000 in Schwyz and St. Gallen and CHF 646,700 in Lucerne, with Geneva at CHF 425,194 and Vaud at CHF 415,000 plus a supplement to cover wealth tax. Zurich, Basel-Stadt, Schaffhausen and Appenzell Ausserrhoden do not offer the regime, and Basel-Landschaft no longer admits new beneficiaries. In practice, the effective annual tax bill is negotiated through an advance ruling with the cantonal tax office.
Immigration is a separate question. EU and EFTA nationals who are not working can reside under the Agreement on the Free Movement of Persons by showing sufficient means and health insurance. Third-country nationals need an exception to the admission limits: either a permit under Art. 30(1)(b) of the Foreign Nationals and Integration Act on grounds of significant cantonal fiscal interest — where cantons usually expect a substantial annual tax contribution — or the retiree route for persons aged 55 and over with close ties to Switzerland. Both require cantonal support and federal approval by the State Secretariat for Migration.
Wealth planning in Switzerland also involves cantonal inheritance and gift taxes, which most cantons do not levy on spouses and direct descendants. A federal popular initiative to introduce a 50% federal tax on very large estates was rejected by voters on 30 November 2025, removing a significant uncertainty for wealthy families considering a move.
Key benefits
- Taxation on living expenses rather than worldwide income and gains, with predictable annual liability
- Advance ruling with the cantonal tax office provides certainty before relocation
- Choice of cantons with markedly different minimum bases, languages and lifestyles
- Political and legal stability, a strong franc and world-class private banking
- Most cantons exempt spouses and direct descendants from inheritance and gift tax
- Schengen membership for travel within Europe
- Excellent international schools, healthcare and personal security
Requirements
- Non-Swiss nationality (dual Swiss nationals are excluded from the lump-sum regime)
- First-time Swiss tax residence, or return after at least ten years abroad
- No gainful activity in Switzerland; managing one's own private assets is generally accepted
- Both spouses must satisfy the conditions where living together
- A Swiss home whose rent or rental value supports the agreed expenditure base (seven times rent rule)
- EU/EFTA nationals: sufficient financial means and Swiss-compliant health insurance
- Non-EU nationals: cantonal confirmation of significant fiscal interest under Art. 30(1)(b) FNIA, or retiree conditions under Art. 28 FNIA (age 55+, close ties, sufficient means)
- Clean criminal record and clear source-of-wealth documentation
Investment options
EU/EFTA national – non-active residence
Sufficient means and health insurance
Residence under the free movement agreement; the lump-sum regime is then requested from the chosen canton through an advance ruling.
Non-EU national – fiscal interest permit
Federal base CHF 435,000 (2026) plus cantonal floor
Exception to admission limits for applicants whose tax contribution represents a significant cantonal interest. The canton sets its expectation and the SEM must approve.
Non-EU retiree (age 55+)
Sufficient means
Residence for retirees with personal ties to Switzerland who give up gainful activity abroad and in Switzerland; may be combined with lump-sum taxation.
Ordinary taxation with business activity
Business plan and job creation
Entrepreneurs who want to work in Switzerland cannot use the lump-sum regime and are taxed ordinarily; admission can be based on economic interest of a new business.
Step-by-step process
- 1
Cantonal comparison
We compare cantons by minimum base, wealth-tax add-ons, inheritance rules, schooling and property market, and model your likely annual tax.
- 2
Tax ruling negotiation
Through local tax counsel, a ruling request is filed with the chosen cantonal tax office to fix the expenditure base before you commit.
- 3
Immigration filing
EU/EFTA nationals register with the commune; non-EU applicants file with the cantonal migration office, which seeks SEM approval.
- 4
Home and visa
A suitable home is rented or purchased (foreign buyers may face Lex Koller limits), and non-EU applicants obtain a national visa where required.
- 5
Arrival and registration
On arrival you register with the commune, take out Swiss health insurance and receive your B permit.
- 6
Annual compliance
You file annual tax returns under the agreed regime and keep the conditions — notably no Swiss gainful activity — in place.
Typical documents
- Passports and civil-status certificates for all family members
- Criminal record extracts
- Statement of assets and source-of-wealth report
- Evidence of income and expected living costs
- Lease or purchase agreement for the Swiss residence
- Swiss health insurance confirmation
- Tax ruling request and confirmation from the cantonal tax office
- Curriculum vitae and evidence of ties to Switzerland (retiree route)
How Legal Wealth helps
Legal Wealth coordinates the full Swiss relocation file: canton selection, tax ruling negotiation with local counsel, immigration filings, banking and the alignment of trusts, holding companies and succession plans with Swiss rules. We work on a compliance-first basis, documenting source of wealth thoroughly, and keep the process discreet from the first feasibility discussion to annual follow-up.
Enquire with Legal WealthFrequently asked questions
How much tax will I pay under the lump-sum regime?
It depends on the canton and your living costs. The taxable base is at least CHF 435,000 at federal level for 2026 and at least seven times your annual rent, with cantonal floors ranging from CHF 200,000 to over CHF 600,000. Effective annual tax usually falls in the low-to-mid six figures, confirmed by ruling.
Can I work while taxed on expenditure?
No gainful activity is allowed in Switzerland. Activities abroad may be compatible, and managing your own private assets is generally accepted, but this should be agreed in the ruling.
Which cantons do not offer lump-sum taxation?
Zurich, Basel-Stadt, Schaffhausen and Appenzell Ausserrhoden, and Basel-Landschaft does not admit new beneficiaries. Geneva, Vaud, Valais, Ticino, Zug, Bern and Graubünden are frequently considered.
Is the lump-sum regime enough to obtain a permit as a non-EU national?
Not automatically. The canton must confirm a significant fiscal interest and the State Secretariat for Migration must approve. Cantons typically expect a higher tax contribution from non-EU applicants than the legal minimum.
What happened to the federal inheritance tax initiative?
Swiss voters rejected it on 30 November 2025. Inheritance and gift taxes remain cantonal, and most cantons exempt spouses and children.
Can I become Swiss later?
Ordinary naturalisation generally requires ten years of residence and a C permit, plus integration and language criteria. Becoming Swiss ends eligibility for lump-sum taxation.
Last reviewed: 2026-10. Requirements, fees and timelines change. Information is general, reviewed on the date shown, and is not legal or tax advice.
