Swiss Lump-Sum Taxation for HNWIs: Eligibility and Planning
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Eligibility Requirements
Expenditure-based taxation is available to qualifying foreign nationals who become Swiss tax resident for the first time or after at least ten years abroad and do not undertake gainful activity in Switzerland. Both spouses living together must meet the conditions. Managing a business or family office from Switzerland needs specific assessment; foreign clients or ownership alone do not establish eligibility.
How the Taxable Base Is Calculated
For tax year 2026, the federal minimum assessment base is CHF 435,000, not the tax payable. Worldwide living expenses and statutory housing-based minimums must also be considered. A separate control calculation can increase the tax due on specified Swiss income and treaty-relieved foreign income. Cantonal income and wealth-tax rules require a separate calculation.
Which cantons should you compare?
Zürich abolished cantonal expenditure-based taxation in 2010. Schaffhausen, Appenzell Ausserrhoden, Basel-Landschaft and Basel-Stadt also abolished it. For other cantons, obtain the current requirements from the relevant tax authority. A single national table of minimum payments cannot establish your eligibility or final liability.
The Application Process: Step by Step
Before choosing a canton, assemble passports, residence history, a worldwide household budget, housing details, income sources and intended work activities. Coordinate a comparison with ordinary taxation and, where appropriate, a written ruling request through qualified tax specialists. Confirm its assumptions and reporting duties. Tax treatment and immigration permission are separate decisions; neither approval nor a fixed annual tax bill is guaranteed.
Founders: describe your role after the move
If you are preparing a business exit, distinguish ownership from the work you will continue to perform. List board positions, consulting agreements, management duties and any earn-out conditions. Ask your tax and immigration advisers to assess the proposed activities together before relying on a private-wealth residence plan. The location of customers or the company’s registered office does not, on its own, settle how work performed from Switzerland will be treated.
Questions for the first assessment
Bring a broad summary of citizenship, residence history, family members, intended activities and the countries connected to your assets. Compare the household’s expected spending, housing and specialist costs alongside the tax analysis. A useful outcome is a written list of assumptions, unresolved questions and the next authority or adviser decision. Keep transaction deadlines separate from proposed relocation dates until the dependencies are understood.
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