BPROL

EXPENDITURE-BASED TAXATION

Swiss Lump-Sum
Taxation

Residence and tax planning for qualifying foreign nationals

Cantonal
Location-specific assessment
CHF 111–146k
A couple's annual tax at the minimum base
Separate
Tax and residence approvals
01

Swiss lump-sum taxation at a glance

A known tax base, and a life in Switzerland

Known in the market as lump-sum taxation or Swiss non-dom; in law, taxation on expenditure.

WHAT YOU OBTAIN

Agreed base, Swiss home

Tax assessed on living expenditure, with the base agreed in a written ruling and residence in the chosen canton.

WHO IT SUITS

Families making the move

Foreign nationals new to Swiss tax residence, or returning after ten years away, with no gainful activity there.

ANNUAL TAX

From CHF 111,000 a year

At the minimum base, a married couple pays about CHF 111,000 (Zug) to 146,000 (Lugano) a year.

FAMILY

Spouses assessed together

Spouses living together share one assessment and each meets the conditions. The base covers dependants' living costs.

PRESENCE AND RESIDENCE

Life centred in Switzerland

The family home is in Switzerland. Geneva asks third-country nationals to spend most of the year there.

MAIN STAGES

Two linked approvals

Canton and home, tax ruling, residence permit, the move, then the yearly assessment, in one file.

WHY FAMILIES CHOOSE SWITZERLAND

A known basis of taxation

The base follows living expenditure and housing cost and is recorded in a written ruling. Ordinary rates apply.

A simplified assessment

Expenditure replaces the usual assessment of income; the same calculation covers cantonal wealth tax.

Long-term value for Schengen travel and citizenship planning

A B or C permit gives visa-free travel across Schengen; time on either counts towards citizenship.

Who qualifies

02

Who qualifies

ConditionRequirementIn practice
NationalityForeign nationals. Swiss citizens are taxed under the ordinary system.Both spouses hold foreign nationality.
Residence historySwiss tax residence for the first time, or a return after at least ten years away.Earlier stays in Switzerland are listed with dates.
ActivityNo gainful activity in Switzerland.Executive, board, consulting and remote work is reviewed before the move. Managing the family's own assets is permitted.
SpousesWhere spouses live together, each of them meets every condition.One assessment for the couple, covering dependants' living costs.
Home in SwitzerlandTax domicile in Switzerland: the family makes its home there.The rent or rental value of the home enters the tax-base calculation.
Canton21 of the 26 cantons apply the regime to cantonal tax; they are listed in “What the regime gives your family”.Zurich, Schaffhausen, Appenzell Ausserrhoden, Basel-Landschaft and Basel-Stadt use ordinary cantonal taxation.

KEY FIGURES

10Years of absence before a return qualifies
7×Annual housing cost: the comparison figure
CHF 111–146kA couple's annual tax at the minimum base
21Cantons apply the regime

An eligibility review of both spouses, made before the home is chosen, settles the canton, the residence category and the tax-base calculation in one sequence.

Application eligibility · Non-EU nationals

03

Application eligibility · Non-EU nationals

Applicant / familyAge and conditions
Main applicantAge not specified; Foreign national establishing Swiss tax domicile for the first time or after ten years abroad, without Swiss gainful employment. Spouses living together must both qualify
SpouseAge not specified; Provide a valid marriage certificate
Minor childUnder 18; Include birth or adoption and custody documents; parental consent where required; Age at application
Adding family laterLater family applications are assessed separately under the rules in force at that time
Nationality restrictionsSwiss citizens cannot use lump-sum taxation. EU/EFTA residence and third-country fiscal-interest residence follow different permit rules
Who the restrictions coverDisclose all current and former nationalities, birthplace and residence history for the applicant and family
Residence conditions and exceptionsTen years abroad is a tax-history condition, not a sanctions waiver. No age-55 rule is stated for Geneva’s fiscal-interest permit; the retiree route is separate
Sanctions and background checksBackground, security and source-of-funds checks apply. Sanctions affecting a person, bank or transfer can prevent completion

Application eligibility · EU and EFTA nationals

04

Application eligibility · EU and EFTA nationals

Applicant / familyAge and conditions
Main applicantAge not specified; Foreign national establishing Swiss tax domicile for the first time or after ten years abroad, without Swiss gainful employment. Spouses living together must both qualify
SpouseAge not specified; Provide a valid marriage certificate
Child under 21 or dependentAge not specified; Children under 21, or older children who are dependent, under free-movement family rules
Parents of either spouseAge not specified; Must be financially dependent on the applicant
Adding family laterLater family applications are assessed separately under the rules in force at that time
Nationality restrictionsSwiss citizens cannot use lump-sum taxation. EU/EFTA residence and third-country fiscal-interest residence follow different permit rules
Who the restrictions coverDisclose all current and former nationalities, birthplace and residence history for the applicant and family
Residence conditions and exceptionsTen years abroad is a tax-history condition, not a sanctions waiver. No age-55 rule is stated for Geneva’s fiscal-interest permit; the retiree route is separate
Sanctions and background checksBackground, security and source-of-funds checks apply. Sanctions affecting a person, bank or transfer can prevent completion

The annual tax and the family budget

05

The annual tax and the family budget

First the tax base, then the tax

The base is the highest of three figures, reviewed each year; ordinary rates then apply.

ANNUAL TAX AND THE FEDERAL MINIMUM BASE

CHF 111,000–146,000A married couple's annual tax at the minimum base, four locations
CHF 435,0002026 federal minimum tax base

ANNUAL TAX AT THE MINIMUM BASE, MARRIED COUPLE, 2026

Federal taxCantonal taxCommunal taxWealth tax
ZugCHF 111,358
GstaadCHF 130,226
LuganoCHF 146,259
GenevaCHF 144,263

Single applicants: CHF 115,016 (Zug) to 160,328 (Geneva). 2026 rates; church and personal taxes excluded.

YOUR FIGURES

CHF 72,000
Housing comparison figure
CHF 504,000
2026 federal minimum tax base
CHF 435,000
The tax base is at least
CHF 504,000

Living expenditure applies where it is higher; each canton sets its own cantonal minimum.

SETTING THE TAX BASE

Worldwide living expenditureActualTaxpayer and dependants, in Switzerland and abroad
Housing comparison figureCHF 72,000CHF 504,000 for a CHF 72,000 rent (seven times), above the federal minimum

FROM THE BASE TO THE TAX

Tax ratesOrdinary
Cantonal wealth taxBy cantonZug 20× the base · Lugano 5× · Geneva +10% · Bern property

YEARLY COSTS

Annual taxCHF 111k–146k
Home and insuranceBy householdHousing, health cover, social insurance
Ruling and filingsQuoted
Tax adviser and lawyer service feeQuoted case by case
The following overview of optional services and estimated market rates for third-party professional services is provided strictly for budgeting purposes. These figures are not BPROL quotes and do not represent fees you are required to pay to any service provider. You may choose a provider that meets the programme’s requirements and engage services as needed.
Tax rulingapplying to the cantonal tax authority and agreeing the tax base
Residence permitapplication and follow-up
Annual assessmentexpense records and annual review
Optional servicesrelocation and bank account, quoted separately
Separate from the subtotal above

Process and payment schedule

06

Process and payment schedule

Tax ruling and residence permit, in one plan
StageYou prepareIn personPaymentYou obtain

The order of ruling, permit application, housing commitment and family move is agreed at the outset, and both authorities receive the same account of the family.

What the canton reviews

07

What the canton reviews

One coherent file serves the tax office and the migration office alike: income, assets, spending and activities, described the same way in each.

Financial and tax evidence

  • Asset and income schedule
  • Source-of-wealth records
  • Annual worldwide living expenditure
  • Expected housing cost: rent or rental value
  • Swiss-source income and assets
  • Income claiming treaty relief

Residence and family records

  • Passports
  • Civil-status records
  • Certificate of criminal record, where required
  • Lease, purchase or housing plan
  • Letter setting out the reasons for the move
  • EU/EFTA nationals: proof of means and health insurance

Activities and the ruling

  • CV
  • Account of executive, board, consulting and remote work
  • Undertaking to carry on no gainful activity in Switzerland
  • Tax ruling stating the base and conditions
  • Assessment assumptions and yearly review duties
  • Residence permit decision for each family member

Kept current, the same file supports each yearly assessment. A change of work, home or canton is reviewed with the adviser before it takes place, so that the arrangement continues to fit the facts.

What the regime gives your family

08

What the regime gives your family

21
cantons to make a home in
Cantons applying expenditure-based taxation to cantonal and communal tax

THE 21 CANTONS

Lake Geneva and the west

  • Geneva
  • Vaud
  • Valais
  • Fribourg
  • Neuchâtel
  • Jura

Bern and central cantons

  • Bern
  • Lucerne
  • Zug
  • Schwyz
  • Uri
  • Obwalden
  • Nidwalden

North, east and south

  • Aargau
  • Solothurn
  • Thurgau
  • St Gallen
  • Appenzell Innerrhoden
  • Glarus
  • Graubünden
  • Ticino

TAX

About CHF 111,000–146,000 a year

Federal, cantonal and communal tax is computed on the base in the written ruling, in place of the usual assessment of income. At the minimum base, a couple pays about CHF 111,000 (Zug) to 146,000 (Lugano) a year.

HOME

A family home in Switzerland

The family lives in the canton and commune of its choice, with residence permits for spouse and children handled in the same file.

TRAVEL

Visa-free travel across Schengen

A Swiss B or C permit allows visa-free entry to the other Schengen states for up to 90 days in any 180-day period, whatever the holder's nationality.

SUCCESSION

No federal inheritance or gift tax

Inheritance and gift taxes are cantonal, and spouses and descendants are normally exempt. Schwyz and Obwalden levy no inheritance tax.

Your path to citizenship

09

Your path to citizenship

Years of residence count towards citizenship

Ordinary naturalisation is open after ten years of residence, with the C permit in hand.

  1. Residence in SwitzerlandTime on a B or C permit counts
  2. C settlement permitHeld when the application is made
  3. Ten qualifying yearsThree within the five years before applying
  4. Language and integrationSpoken B1, written A2
  5. Swiss citizenshipDecided by commune, canton and Confederation

Residence that counts

Adults generally need ten qualifying years in Switzerland, three of them in the five years before applying, and a C settlement permit at the time of application. Time on a B or C permit counts. Canton and commune usually ask for two to five years locally.

Language and integration

The federal standard is B1 speaking and A2 writing in a national language; a canton may set a higher level. Familiarity with Swiss life, local ties, financial self-sufficiency and tax and legal obligations kept in good order complete the assessment.

Citizenship and taxation

Commune and canton examine the application; federal authorisation precedes the canton's final decision. Switzerland has recognised dual nationality since 1992. From naturalisation the family is taxed under the ordinary system, so the change is modelled beforehand.

Speak with your adviser

10

Speak with your adviser

Request a canton comparison, a written tax-base calculation and a separate residence-permit assessment.

Compare your family options →

HOW TO APPLY

  1. Assessment

    We review your family, aims and eligibility, and say plainly whether the programme fits.

  2. Written proposal

    You receive an itemised quotation, a document list and a timetable in writing.

  3. Engagement and filing

    Once engaged, we prepare the file, submit it and follow it through to the decision.

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bih.l@bprol.com

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