Author: Maria Plotnikova
Attorney, Family Office
Concept
The Lump-sum taxation regime (pauschalbesteuerung in German or imposition forfaitaire in French) is a unique Swiss tax system that enables high-net-worth individuals to obtain Swiss tax residency by paying a fixed annual tax in lieu of declaring global income and assets.
This system has existed in Switzerland since the 1920s and was originally designed to attract wealthy retirees and rentiers from abroad. Today it remains one of the most attractive instruments for international tax planning, particularly for family offices and the management of global assets.
The key advantage of this regime lies in the complete exemption from the obligation to declare foreign income and assets. Swiss tax authorities do not require disclosure of global income sources, offshore structures or foreign investments.
Advantages
The Lump-sum taxation regime offers the following benefits to eligible foreign nationals:
- Financial confidentiality: no obligation to disclose foreign income or assets
- Predictability of tax obligations: pre-agreed and fixed tax amount
- Relief from double taxation: Switzerland has an extensive network of double taxation treaties
- No inheritance tax: between spouses and direct descendants in most cantons
- Access to European mobility: Swiss residency allows free movement within the Schengen Area
- High compliance reputation: internationally recognised Swiss tax residency
Residents subject to fixed taxation may face restrictions in accessing certain treaty benefits under Switzerland’s double tax agreements.
Comparison with standard taxation
Lump-sum taxation | Standard taxation | |
Rate | CHF 200,000–400,000 minimum (depending on canton) | Progressive scale up to 45% (depending on income and canton) |
Declaration of global income | Not required | Mandatory |
Declaration of foreign assets | Not required | Mandatory |
Swiss-sourced income | Taxed separately | Included in general tax base |
Wealth tax | Applies only to Swiss assets | Applies to worldwide assets |
Treaty benefits | Limited | Full access |
Calculation
Lump-sum taxation is based on the taxpayer’s annual living expenses and calculated using the formula:
Lump-sum tax = Monthly rental cost × 12
For example if the monthly rent is CHF 10,000, the annual tax would be calculated as 20,000 × 12 = CHF 240,000.
However the total amount payable cannot be lower than the minimum threshold set by the respective canton:
Canton | Minimum (CHF) |
Geneva | 400,000 |
Bern | 400,000 |
Zurich | 350,000 |
Appenzell Ausserrhoden | 300,000 |
Graubünden | 300,000 |
Lucerne | 300,000 |
Ticino | 300,000 |
Vaud | 250,000 |
Zug | 250,000 |
Valais | 250,000 |
Nidwalden | 200,000 |
Obwalden | 200,000 |
Schwyz | 200,000 |
Eligibility criteria
To qualify for the lump-sum taxation regime an applicant must:
- Not hold Swiss citizenship
- Be a first-time Swiss tax resident or not have resided in Switzerland in the past 10 years
- Not be gainfully employed in Switzerland (investment management and board memberships are permitted)
- Demonstrate sufficient income and assets to support the fixed tax basis
Not all Swiss cantons offer the lump-sum taxation regime. The cantons of Zurich, Schaffhausen, Basel-Stadt, Basel-Landschaft and Appenzell Innerrhoden have abolished it entirely. The remaining 21 cantons maintain the regime with varying conditions and minimum thresholds.
Family members
Spouse
— Legally recognised marriage required
— Civil partnerships recognised if cohabitation has lasted 2–3 years | Children under 18
— Included automatically
— Applies to biological children and those under legal guardianship |
Parents of the applicant
— Minimum age 65 (or 60 in some cantons)
— Financial dependence must be documented
— Medical grounds for cohabitation may be required
— Proof of relationship via notarised documents | | Children aged 18–25
— Proof of financial dependence
— Unmarried with no children
— Full-time university enrolment
— Living with the applicant | |
Application process
Subject to timely document preparation the Swiss residence permit (Permit B) may be issued within 4–6 months.
Visit 1: Submission of documents
Document collection, legalisation and translation takes 1–2 months. Investments or the lump-sum tax must be arranged before the visit. On the day of arrival, the entry stamp is obtained and the full application is submitted to the cantonal immigration authority.
Visit 2: Biometrics (after 45–60 days)
Authorities review the file including verification of assets or investments, criminal background and health insurance. The applicant returns to Switzerland to provide biometric data (fingerprints and photo) upon receiving conditional approval.
Visit 3: Permit issuance (after 30–45 days)
Within 30–45 days after the second visit the physical residence card is issued. The applicant must be present to collect the permit and activate residency status.
Required documents
All documents must be translated into the official language of the canton (German, French or Italian) and legalised with an apostille.
Document | Requirements |
Passport | Full copy of all pages; valid for at least one year |
National ID | Full copy of all pages |
Photos | Colour, biometric, 35×45 mm, six copies |
Marriage certificate | Recently issued duplicate |
Birth certificates | For all dependent children |
Criminal record certificates | Issued within last 3 months; required from country of citizenship and all countries of residence in the past 5 years |
Financial records | Bank statements or tax returns (for lump-sum tax) or investment documentation (for investment-based residence) |
Proof of source of funds | Business records, asset sale, inheritance, etc. |
Employment history | Past 5 years: CV, reference letters, corporate records |
Tax returns | For the last 3 years |
Proof of accommodation | Lease agreement or property ownership documents in Switzerland |
Health insurance | Swiss comprehensive insurance for all family members |
Contact Information
If you have any questions or require a consultation, our experts will be happy to assist you.
Private.law Attorneys
This material is provided for public informational purposes and is freely shareable.
We specialise in solving complex legal challenges for discerning clients. 🍓