Pre-Immigration Tax Planning for HNWIs & Founders
Map business ownership, investments and planned transactions before moving. Coordinate Swiss and departure-country tax advice.
Overview
Before establishing Swiss tax residence, map shareholdings, trusts, pensions, property, debts, planned disposals and the countries involved. Collect ownership records, valuations and source-of-wealth evidence. Ask your existing and Swiss specialists to assess departure taxes, treaty residence and the consequences of each transaction. Do not assume that selling before arrival is tax-free or that a foreign structure retains its treatment in Switzerland.
Documents to prepare
Prepare passports and residence history for each family member, civil-status records, intended housing and insurance details, and evidence of income and assets. For business owners, include ownership charts, accounts and planned transactions. Share sensitive records only through the channel agreed for the engagement; the initial enquiry does not need a full financial dossier.
Process and deliverables
The initial assessment identifies your proposed residence basis, canton shortlist and unresolved specialist questions. The agreed engagement can then set out a document checklist, responsibilities and the sequence for tax, immigration, housing and banking. Legal opinions, tax filings and regulated financial services require the appropriate professionals and mandates. Confirm the scope and fees before work starts.
Timing and fees
Plan around document availability, specialist analysis, authority requests and family commitments. Approval dates cannot be guaranteed. Ask for a written scope separating coordination fees, specialist fees and official charges, with assumptions and exclusions. The first discussion should establish your target arrival date and the decisions that must precede it.
Questions to resolve
What residency permits are available in Switzerland?
B is a residence permit, L a short-stay permit, C a settlement permit and G a cross-border commuter permit. The appropriate category and its conditions depend on nationality, purpose of stay and the authority’s decision. For non-EU/EFTA nationals, the legal basis must be assessed individually. Employment, self-employment, retirement and exceptional admissions have different requirements. Wealth, a property purchase, company incorporation or a tax ruling does not by itself confer a residence permit. Cantonal and, where required, federal authorities decide; obtain an assessment before committing to a move.
What is lump-sum taxation (forfait fiscal) in Switzerland?
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.

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