THE SWISS LUMP-SUM REGIME — home

The Optimum Fiscal Architecture for Global Wealth

Assessed on Your Expenditure, Not Your Worldwide Income.
The Swiss Expenditure-Based Taxation.

Establish tax residence in Switzerland and be assessed on your annual living expenditure instead of your worldwide income and wealth. The basis of assessment is set by federal and cantonal law, and you remain fully liable to Swiss tax — what changes is how that liability is calculated.

Technical Architecture

Expenditure-based
Taxation (Lump-Sum)

Expenditure-based taxation — commonly called the lump-sum regime, or forfait fiscal — is a separate method of assessment open to foreign nationals taking up residence in Switzerland. The law sets the conditions: no Swiss citizenship, unlimited tax liability here for the first time or after at least ten years away, and no gainful activity in Switzerland. The tax is then computed on the annual expenditure of the taxpayer and the persons they support, incurred in Switzerland and abroad, rather than on worldwide income and wealth.

This regime provides fiscal certainty and administrative simplicity. A mandatory "control calculation" (Kontrollrechnung) ensures that the final tax due is not lower than the tax calculated on specific Swiss-sourced assets and income (e.g., Swiss real estate, Swiss securities).

2026 Minimum Tax Base Rules

The minimum tax base is strictly defined as the highest of the following three criteria:

  1. Your total annual worldwide living expenses.

  2. Seven times your annual Swiss rent or the rental value of your primary Swiss residence.

  3. The federal minimum threshold of CHF 435,000.

JURISDICTIONAL NUANCE

Cantonal practice differs, and not every canton publishes a figure of its own. Where a canton does not, the indexed federal minimum applies; where it does, the cantonal figure governs. We work from the published cantonal sources and confirm the position with the competent authority before any commitment is made.

We prepare and present your position to the competent cantonal authority, and tell you plainly what the regime will and will not do for you. The assessment is the authority's to make, not ours.

Eligibility Legal Requirements

Nationality

Applicants must hold non-Swiss citizenship.

Fiscal Domicile

Applicants must establish a fiscal domicile in Switzerland for the first time, or return after a minimum absence of 10 years.

Economic Activity

The taxpayer must not exercise any gainful activity within Switzerland. The management of private assets is explicitly permitted.

Non-EU/EFTA Protocol

Non-EU/EFTA nationals fall under a different admission regime, with cantonal quotas and a federal approval stage. We prepare the file that regime requires and follow it through both stages.

Cantonal Tax Availability 2026

As of 2026, expenditure-based taxation is in force for cantonal and communal taxes in 21 of the 26 Swiss cantons.

Important Note on Federal Tax:

Under federal law the regime remains available for direct federal tax even in the five cantons that have abolished it for their own taxes. Moving to one of those five rarely makes sense: worldwide income and wealth remain fully subject to ordinary taxation at cantonal and communal level.

Exclusive Asset Analytics

Simulate Your Swiss Tax Structure

The assessment base is not a rate applied to your wealth. It is the highest of three statutory figures — your worldwide living expenditure, seven times the rent or rental value of your Swiss home, and the minimum set by federal and cantonal law — and the tax follows from the ordinary tariff of the commune you settle in.

In preparation

The expenditure simulator is being rebuilt so that it shows how the assessment base is determined rather than quoting a single figure of tax due. The tax payable on a given base depends on the commune of residence and is set by the cantonal authority, not estimated here.

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Institutional

Credibility & Trust

15+

Years of Excellence

250+

Successful Relocations

CHF 1bn+

Combined wealth of relocated families

For Professional Intermediaries

Partnering with Family Offices & Private Banks

We provide specialized support for legal counsel, wealth managers, and family offices navigating the complexities of Swiss relocation for their ultra-high-net-worth clients.

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Why Choose
The Swiss Lump-Sum Advisory?

Swiss tax law and the immigration procedure interact, and a request that is complete and correctly framed is decided on its merits rather than sent back. We prepare the file so that the authority has what it needs the first time.

Proactive 2026 Strategy:

Swiss personal taxation is changing: the federal law on individual taxation was accepted in the referendum of 8 March 2026 and enters into force at the latest in 2032, the cantons being required to adapt their own law by then. We track what actually applies to your position, and say so when a change does not.

Your Path to Swiss Residency

Relocating to Switzerland under the expenditure-based regime requires meticulous planning. Our four-step process is designed to make each stage predictable; the assessment itself rests with the cantonal authority.

PHASE 01

Pre-Immigration Planning

We analyze your global wealth structure and lifestyle preferences to select the optimal Canton for your residency.

PHASE 02

Advance Tax Ruling

We prepare and submit the expenditure computation to the competent cantonal tax authority and obtain a binding advance ruling, so that the basis of assessment is settled in writing before you move.

PHASE 03

Residence Permit Application

We manage the comprehensive legal and administrative procedure for obtaining your Swiss residence permit (Permit B).

PHASE 04

Relocation & Compliance

From finding a home to the annual return and the cantonal obligations that follow it, we handle the recurring work and keep the file in order year after year.

Discreet

Typical situations

We act for clients from many countries, and treat every mandate discreetly, within the duties of confidentiality that bind a Swiss fiduciary. The profiles below are illustrative situations, not accounts of particular mandates.

The technology founder

A move from the United States to Vaud, where an international holding structure for intellectual property has to be looked at before the move rather than after it.

The retired industrialist

A move from Northern Europe to Graubünden, where succession planning across three generations has to sit alongside the new Swiss residence.

The financial professional

A move from London to Geneva, with cross-border regulatory duties to be checked and a family office to be set up in Switzerland.

The family leaving Sweden

A move from Sweden to Lugano, where the point at which Swedish tax residence actually ends has to be established under Swedish law before the Swiss position can be settled.

The Norwegian shareholder

A move from Norway to Uri, holding shares in an unlisted company, where the Norwegian treatment of unrealised gains on emigration has to be established before the Swiss expenditure computation is filed.

The couple with one working spouse

A household in which one spouse intends to go on working. Spouses living in a joint household must both satisfy the conditions for the regime, so the question is decided for the household and not for one person.

Frequently Asked Questions

Can I work in Switzerland under the expenditure-based regime (forfait fiscal)?

No. Gainful activity in Switzerland, employed or self-employed, is incompatible with the regime, and spouses living in a joint household must both meet that condition. Managing your own private assets is not gainful activity and remains permitted.

What is the minimum tax base for 2026?

The base is the highest of three amounts: your annual expenditure in Switzerland and abroad; seven times your annual rent or the rental value if you keep your own household; and the federal minimum of CHF 435,000. Each canton also sets its own minimum for cantonal and communal tax, which may be higher or lower than the federal one. Separately, a mandatory control calculation compares the tax on that base against the ordinary tax on your Swiss-source income and assets, and you pay whichever is higher — it does not change the base, it sets a floor under the tax.

Does every Swiss canton operate the regime?

No. Twenty-one cantons operate it for their own taxes; five — Zurich, Schaffhausen, Appenzell Ausserrhoden, Basel-Stadt and Basel-Landschaft — have abolished it. Direct federal tax is unaffected, so the regime still applies federally even in those five.

Your legacy deserves the utmost
protection and discretion.

Partner with the experts behind The Swiss Lump-Sum Advisory to navigate your relocation to Switzerland with confidence and precision.

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