The whole picture
Wealth structuring
Bringing entities, holdings, residence and succession into one coherent structure around the move.
Wealth structuringRelocation &
lump-sum tax
Expenditure-based taxation lets a qualifying foreign national be taxed on living expenditure rather than worldwide income: a legitimate, long-established Swiss regime, not a loophole. But the attractive headline depends on three things solved together: the right canton, a tax ruling negotiated and accepted by the authority, and a residence permit that actually lets you move. We model the base, secure the ruling, and coordinate the permit, so the relocation is executable, not just appealing on paper.
At a glance
Taxed on expenditure, not worldwide income.
Canton, ruling and permit, solved together.
- Who
- Foreign nationals, no Swiss work
- Federal floor
- CHF 400k base, indexed
- Min base
- ≥ 7× rent / rental value
- Agreed
- In a ruling with the canton
- Comes with
- A residence permit
The essentials
What lump-sum taxation is
Expenditure-based taxation, set out in the federal direct-tax law and described by the federal portal, taxes a qualifying foreign national on annual living expenditure rather than actual worldwide income and wealth. The base is floored by statute, agreed in advance with the canton, and taxed at ordinary rates. It is available only to foreign nationals taking Swiss residence without gainful activity here. The regime is durable (reaffirmed by a 2014 national vote), but the canton, the ruling and the permit must be solved as one.
Who this is for
- internationally mobile individuals of substantial means;
- foreign nationals taking Swiss residence without working here;
- families weighing canton, lifestyle and tax together;
- entrepreneurs who have exited or stepped back from active roles.
Where it fits
Relocation usually connects to wealth structuring, succession planning and opening a Swiss bank account.
The numbers
How the base is calculated
The tax base is the higher of real living expenditure and the statutory minimums, agreed with the canton and taxed at ordinary rates.
| Element | How it works |
|---|---|
| Federal minimum base | CHF 400,000 in statute, indexed (~CHF 430k, 2025) |
| Rent multiple | At least 7× annual rent or rental value |
| Cantonal minimum | Set by each canton, often higher |
| Control calculation | Not below ordinary tax on Swiss-source items |
Because cantons differ markedly on both minimums and rates, the canton is chosen on the modelled outcome and the lifestyle together, not on a headline figure. We run the numbers for the relevant cantons against a realistic residence before any commitment, so the agreed base is one the authority will accept and the client can live with.
The map
Which cantons offer it
Lump-sum taxation is a federal regime, but each canton decides whether to offer it for its own taxes, and five have abolished it by popular vote. Where you can take it, and where you cannot, narrows the choice before lifestyle does.
| Status | Cantons | Note |
|---|---|---|
| Abolished (cantonal) | Zurich, Schaffhausen, Basel-Stadt, Basel-Landschaft, Appenzell AR | Not available for cantonal tax |
| Offered, popular | Geneva, Vaud, Valais, Ticino, Graubünden | Established practice; cantonal minimums apply |
| Offered | Most remaining cantons | Central-Swiss cantons among the lower-rate options |
Note the asymmetry: even an abolishing canton’s residents still pay the federal lump sum. Abolition removes only the cantonal and communal layer, which is the larger part. For most clients the real choice is among the French-speaking and central cantons that actively welcome the regime. We shortlist on the agreed base, the rate and the residence permit together, because the canton that models best on tax is not always the one that grants the permit most readily.
How it runs
How the relocation runs
Model the canton, negotiate the ruling, coordinate the permit, then settle the practicalities, in that order.
- Step 1
Confirm eligibility
Checking nationality, residence history and the no-Swiss-activity condition before anything is planned around the regime.
- Step 2
Model the cantons
Comparing the base, rate and treaty position across candidate cantons against a realistic residence.
- Step 3
Negotiate the ruling
Presenting the case to the chosen canton’s authority and securing an accepted, sustainable expenditure base.
- Step 4
Coordinate the permit
Running the residence permit in parallel, so the tax arrangement and the right to move align.
- Step 5
Settle in
Handling registration, banking and the wider structuring once the move is executable.
Budget
What it costs
The advisory fee depends on the complexity of the affairs, the number of cantons modelled and whether the work extends into wider structuring and the permit. The annual tax itself is the agreed base at ordinary cantonal and federal rates, modelled up front so the client knows the figure before committing.
We scope and quote against the situation. Advisory pricing is on request.
Discuss your move
What it takes
What the regime requires
A lump-sum arrangement that holds rests on:
- foreign nationality and qualifying residence history;
- no gainful activity carried on in Switzerland;
- a canton that offers the regime and suits the family;
- a ruling negotiated and accepted by the authority;
- a residence permit secured in parallel.
When lump-sum taxation is the wrong answer
The regime does not suit everyone it first attracts. Someone who wants to work or actively run a business in Switzerland cannot use it. Someone whose income comes largely from a treaty country that limits benefits for lump-sum taxpayers may pay more, not less, once the treaty position is accounted for. And in a canton with a high minimum base, an individual of more modest means can find ordinary taxation cheaper. The honest analysis sometimes ends in “not this regime” or “not this canton”, which is why the modelling comes before the move, not after.
Why Goldblum
The move: the work behind it
A relocation that works is the tax ruling, the permit and the practicalities solved as one. Running all three, for cross-border families, is the work this firm does.
Modelled
The numbers before the move
The lump-sum base compared across cantons against a realistic residence, so the canton is chosen on a full picture, not a headline rate.
Negotiated
A ruling that is accepted
The expenditure base presented to and agreed with the cantonal authority — predictable, sustainable, and secured before commitment.
Executable
Permit solved in parallel
The residence permit coordinated alongside the ruling, so the move is one the family can actually make, not just an attractive plan.
Related
Around the move
The next generation
Succession & estate planning
Wills, choice of law and forced-heirship planning for a cross-border family settling in Switzerland.
Succession & estate planningAccess
Swiss bank account
The introduction and source-of-wealth file that get the account opened once you arrive.
Swiss bank account
FAQ
Lump-sum taxation: FAQ
01What is Swiss lump-sum taxation?
Lump-sum taxation (expenditure-based taxation, the forfait fiscal) is a Swiss tax regime under which a qualifying foreign national is taxed not on actual worldwide income and wealth but on annual living expenditure. The tax base is agreed in advance with the cantonal authority, subject to statutory minimums, and that base is then taxed at ordinary rates. It is a legitimate, long-established regime, not a loophole: it is available only to foreign nationals taking up Swiss residence who do not pursue gainful activity in Switzerland, and the base is floored, controlled and negotiated. For internationally mobile individuals of substantial means, it can make Swiss residence both attractive and predictable.
02Who qualifies for lump-sum taxation?
Three conditions, broadly: the person must be a foreign national (Swiss citizens cannot use it); taking up Swiss tax residence for the first time or after at least ten years abroad; and not engaged in any gainful activity in Switzerland. Income from managing one's own foreign assets is fine; working for or running a Swiss business is not. A married couple where one spouse is a Swiss citizen, or where a spouse works in Switzerland, cannot use the regime. The conditions are specific and the authorities apply them strictly, so eligibility should be confirmed before the move is planned around it.
03How is the tax base calculated?
The base is the higher of the person's actual annual worldwide living expenditure and a set of statutory minimums. For federal direct tax the minimum living-expense base is CHF 400,000 in the statute, indexed periodically (around CHF 430,000 for 2025) and in every case the base must be at least seven times the annual rent or rental value of the residence the person occupies. Cantons set their own minimums, often higher. A control calculation also ensures the lump-sum tax is no lower than ordinary tax on Swiss-source income and certain assets. We model the likely base for a given canton and residence before anything is committed.
04Which cantons offer it?
Most cantons offer expenditure-based taxation, but not all: Zurich abolished it by popular vote, and a handful of others followed at cantonal level. It remains available and actively used in cantons such as Geneva, Vaud, Valais, Ticino, Graubünden and several in central Switzerland, with meaningfully different minimum bases and effective rates between them. Choosing the canton is therefore part of the planning, balancing the tax outcome against where the family actually wants to live. We compare cantons on the numbers and the practicalities, so the choice is made on a full picture rather than a headline rate.
05Is the lump-sum amount negotiated?
Yes, within the statutory floors, the expenditure base is agreed in advance with the cantonal tax authority in a ruling, and that agreement is what gives the regime its predictability. The negotiation turns on the credible level of the individual's living expenditure and the canton's own practice and minimums. A ruling secured properly fixes the tax position for the future, subject to the conditions continuing to hold. This is the heart of the work: presenting the case to the authority and securing a ruling that is both accepted and sustainable. We handle that engagement with the canton.
06What residence permit comes with it?
Lump-sum taxation is a tax regime, not an immigration status, and the two have to be solved together. Nationals of EU/EFTA states can generally take residence in Switzerland without gainful activity relatively straightforwardly. Non-EU/EFTA nationals usually rely on a residence permit granted on the basis of substantial fiscal interest to the canton (closely linked to the lump-sum arrangement), which is discretionary and cantonal. The tax ruling and the permit are negotiated in parallel, because each depends on the other. We coordinate both so the move is actually executable, not just attractive on paper.
07Can someone on lump-sum tax work or run a business?
Not in Switzerland. Any gainful activity carried on in Switzerland disqualifies the person from the regime. That is a core condition. Managing one's own private wealth, including foreign assets and companies, is permitted; taking up employment, a board seat with active management, or operating a Swiss business is not. Activity abroad is generally unaffected. The line between permissible asset management and impermissible Swiss activity matters and is sometimes finer than it looks, particularly for entrepreneurs who keep a hand in their businesses. We map a client's intended activities against the rule before they rely on the regime.
08How does lump-sum tax interact with double-tax treaties?
It can, and it needs checking per country. Some of Switzerland's treaty partners restrict treaty benefits for individuals taxed on a lump-sum basis, and a few require a modified lump-sum (taxing certain foreign-source income normally) for the person to claim relief on income from that country. Whether this matters depends on where the individual's income and assets sit. For someone with significant income from a country that limits benefits, the modified regime or a different plan may be better. We check the treaty position for the relevant countries as part of the modelling, so there are no surprises after the move.
09Is lump-sum taxation secure, or could it be abolished?
The federal regime was reviewed and retained (a 2014 national vote to abolish it was rejected, and a 2016 reform tightened the minimums rather than ending it), so it rests on a recently reaffirmed footing. At cantonal level it has been abolished in a few cantons by popular vote, and that remains a political possibility elsewhere. Existing arrangements have generally been protected by transition rules when a canton has changed course. The regime is established and durable, but it is a policy choice, and we factor the canton's political stance into the recommendation rather than treating it as permanent.
10Can Goldblum handle the whole relocation?
Yes. We model the lump-sum base across the relevant cantons, advise on where the numbers and the lifestyle align, negotiate the tax ruling with the chosen canton's authority, and coordinate the residence permit in parallel, then handle the practicalities of arriving, from registration to banking. Where the family's affairs need structuring around the move (a foundation, succession planning, a family office), we connect the relocation to that wider picture. The aim is a move that is executable, defensible and settled before the client commits, not a headline rate that unravels in practice.
Considering a move to Switzerland?
Tell us your nationality, means and where you'd like to live. A partner models the lump-sum base across cantons and maps the route to a ruling and a residence permit.