Swiss lump-sum taxation — guide 2026 | Bensaid Avocats

Hub · Wealth & non-residents — Geneva Office

Swiss lump-sum taxation — imposition d'après la dépense

Switzerland taxes newly-installed foreign nationals on their living expenses rather than on their worldwide income. This regime — imposition d'après la dépense in French, Pauschalbesteuerung in German, lump-sum taxation in English — rests on article 14 of the Federal Direct Tax Act (LIFD) of 14 December 1990 and on cantonal tax laws (LHID art. 6). The federal floor stands at CHF 434,700 for 2025, indexed annually by Federal Council ordinance. The regime is lifetime, subject to ongoing eligibility and to the cantonal political continuity — five cantons abolished the device through popular vote between 2009 and 2014. The Firm, registered with the Geneva Bar, accompanies families, executives approaching exit and international wealth owners through the entire option process: eligibility check, cantonal negotiation, the Kontrollrechnung comparison clause, articulation with the French exit.

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Analysis by Me Jonathan Bensaïd · Tax lawyer · Bensaid Avocats SA · Geneva

At a glance
Calculation base
Multiple of rent (× 7 owners, × 5 tenants) or estimated living expenses — whichever is higher
Federal floor
CHF 434,700 (2025 figure, LIFD art. 14, indexed)
Cantonal floors
VS ≈ CHF 250,000 · VD ≈ CHF 415,000 · GE CHF 400,000 · ZG CHF 750,000
Eligibility
Foreign nationality · no Swiss tax residence in the previous 10 years · no gainful activity in Switzerland
Abolitionist cantons
Zurich (2009), Basel-City (2010), Appenzell A.Rh. (2010), Schaffhausen (2014), Basel-Country (2014)
Duration
Lifetime as long as conditions are met
Comparison clause
Kontrollrechnung — annual recalculation; the higher of the forfait or ordinary tax is due
— 01 — Conviction

A lifetime regime, but not a free pass.

The Swiss lump-sum regime offers an exceptional taxation framework for foreign nationals settling in Switzerland: taxation on living expenses, not on worldwide income. But three pitfalls are common.

The first pitfall is the misreading of the eligibility conditions. Foreign nationality, no Swiss tax residence in the previous 10 years, and no gainful activity in Switzerland are cumulative — assessed each year. A director seat on a Swiss company board is in principle tolerated; receiving attendance fees is not.

The second pitfall is the Kontrollrechnung, the comparison clause under LIFD art. 14 al. 3. Each year, the cantonal administration recalculates a notional ordinary tax on Swiss-source income (Swiss real estate, Swiss bank accounts) and on foreign income exempted by treaty. If this notional ordinary tax exceeds the negotiated forfait, the higher amount is due.

— 02 — The regime in six pillars

The regime in six pillars

The Swiss lump-sum taxation rests on six pillars set by federal law (LIFD art. 14, LHID art. 6) and adjusted at cantonal level. Each pillar requires a concrete decision at the time of the option.

01 · Eligibility — foreign nationality and prior non-residence

Three cumulative conditions (LIFD art. 14, al. 1): (i) exclusive foreign nationality — acquiring Swiss nationality removes the right to the forfait in most cantons; (ii) first installation in Switzerland, or return after at least ten years of absence; (iii) no gainful activity on Swiss territory — private wealth management is admitted, paid operational mandates are excluded. For married couples, both spouses must meet the conditions. A B or C permit is required; its issuance depends on cantonal authority and is not automatic.

02 · Calculation base — multiple of rent or estimated living expenses

The taxable base is the higher of: (i) the federal floor (CHF 434,700 in 2025); (ii) the cantonal floor; (iii) a multiple of rent (× 7 for owners or persons housed for free, × 5 for tenants) or the estimated worldwide living expenses. The cantonal administration assesses the latter through a confidential questionnaire on housing, household staff, vehicles, art collections, education of children.

03 · Comparison clause (Kontrollrechnung) — annual recalculation

Each year, the cantonal administration computes a notional ordinary tax on Swiss-source income (Swiss real estate, Swiss bank accounts) and on foreign income exempted by tax treaty — typically French-source income under the 9 September 1966 convention. If this notional ordinary tax exceeds the negotiated forfait, the higher amount is due (LIFD art. 14, al. 3).

04 · Cantonal floors and effective rates

Each canton sets its own floor and effective rate. Valais and Fribourg stand at around CHF 250,000 of taxable base (effective rate 20–24%). Geneva and Vaud align on the federal floor of CHF 415,000–434,700 (effective rate 25–30%). Ticino sits at CHF 400,000+ (22–26%). Zug requires CHF 750,000 but offers the lowest combined corporate tax rate in Switzerland.

05 · Duration — lifetime subject to ongoing eligibility

The forfait is lifetime, subject to the annual maintenance of the three eligibility conditions and to the political continuity of the regime in the chosen canton. Five cantons abolished the regime by popular vote between 2009 and 2014: Zurich, Schaffhausen, Basel-City, Basel-Country, Appenzell A.Rh. — never reinstated since.

06 · Exit — change of canton, naturalisation, return to France

The forfait ends in case of: (i) acquisition of Swiss nationality (most cantons); (ii) start of a gainful activity in Switzerland; (iii) move to an abolitionist canton; (iv) departure from Switzerland — coordination with the French exit tax (CGI art. 167 bis) becomes critical here, as does the residual French wealth tax (IFI) on French real estate.
— 03 — Cantonal mapping

Cantonal mapping

Five cantons cover the majority of forfait files. Each has its threshold, its dominant language, its quality of life and its administrative responsiveness. The Firm produces a tailored canton-by-canton comparison in week 1 of every engagement.

Vaud — the French-speaking Lake Geneva arc

Cantonal floor ≈ CHF 415,000. Key communes: Lausanne, Montreux, Vevey, Nyon, Morges, Rolle. French-speaking dominant, air access via Geneva. Active welcoming policy of the cantonal tax administration (ACI). See our dedicated Vaud note →

Valais — the most accessible canton

Cantonal floor ≈ CHF 250,000. Key communes: Verbier, Crans-Montana, Sion, Martigny. Mountain quality of life, French and German bilingual, generally shorter instruction times than Vaud or Geneva. See our dedicated Valais note →

Geneva — international banking hub

Cantonal floor CHF 400,000+ (case by case). Dense private banking, top international schools, immediate airport access. More demanding scrutiny but mature administrative responsiveness.

Zug — premium for family offices

Cantonal floor CHF 750,000, but lowest combined corporate income tax in Switzerland (~11.8%). Dense family office concentration, English fluent. See our dedicated Zug note →

Ticino — Italian-speaking proximity

Cantonal floor CHF 400,000+. Italian-speaking, Milan 1h away. Specific appeal for Italian-speaking taxpayers and clients with Italian assets.
— 04 — Approach

Our approach

On the French side, the Firm coordinates the exit from France: anticipating the exit tax under CGI art. 167 bis, assessing the residual IFI (real estate wealth tax) on French real estate, planning donations under art. 750 ter CGI, and managing the cessation of French tax residence vis-à-vis the SIE.

On the Swiss side, the Firm conducts the negotiation with the Administration fiscale cantonale of the chosen canton, prepares the indispensable preliminary ruling, articulates the B permit application with the Office cantonal de la population et des migrations, and coordinates with the Swiss fiduciaries (Treuhand) handling annual accounting. The Firm maintains an ongoing dialogue with the tax administrations of Geneva, Vaud, Valais and Zug — a condition of enforceability of the structures.

— 05 — FAQ

Frequently asked questions

Am I eligible for the Swiss lump-sum regime?
Three cumulative conditions under LIFD art. 14, al. 1. First, you must hold exclusive foreign nationality — a Franco-Swiss dual national is not eligible. Second, you must not have been a tax resident in Switzerland during the previous ten years. Third, you must not exercise any gainful activity on Swiss soil — private wealth management is admitted, but a paid operational mandate, even partial, excludes the benefit of the forfait. For married couples, each spouse must individually meet the three conditions.
What is the federal floor in 2025 and how does it evolve?
The federal floor stands at CHF 434,700 for 2025 (LIFD art. 14, al. 3, c). It is indexed annually by Federal Council ordinance, typically pegged to the consumer price index. The 2026 figure will be confirmed in late 2025. Cantonal floors apply on top: the actual taxable base retained is the higher of the federal floor, the cantonal floor, and the multiple-of-rent or estimated-expenses computation.
How does the Kontrollrechnung work?
The Kontrollrechnung (comparison clause, LIFD art. 14 al. 3) is a recalculation performed annually by the cantonal administration. It computes a notional ordinary tax on Swiss-source income (Swiss real estate, Swiss bank accounts) and on foreign income exempted by tax treaty (typically French-source income under the 9 September 1966 convention). If the resulting notional ordinary tax exceeds the negotiated forfait, the higher amount is due. A very active wealth profile — large dividends from non-resident holdings, mandatory bond portfolio interest — may see the forfait overtaken by ordinary tax.
Which canton is best for me?
It depends on the profile. Valais and Fribourg offer the lowest minimum forfaits (CHF 250,000+, effective rate 20-24%) with shorter instruction times. Vaud and Geneva require CHF 415,000-434,700 (25-30%) but offer top international schools and the most mature banking environment. Zug at CHF 750,000 is premium for family offices and patrimonies of 500 M€+. The Firm produces a tailored comparison in week 1, including a 10-year simulation.
How does the forfait articulate with the French exit?
Three points of attention. First, the exit tax under CGI art. 167 bis on unrealised gains of substantial holdings — automatic deferral under the 21 June 1999 agreement on free movement of persons (to be confirmed by tax counsel for each case). Second, residual IFI on French real estate retained after departure (often subsisting). Third, gifts under art. 750 ter CGI — territoriality assessed at the date of gift, not at the date of acceptance. The Firm coordinates with the Service des impôts des particuliers throughout the cessation of French residence.
— Related

Related pages

Three cantonal notes, the continental arbitrage with Italy, and the structural articulation services.

Cantonal note

Lump-sum taxation — Canton of Vaud

Lausanne, Montreux, Vevey, Nyon — cantonal floor ≈ CHF 415,000, ACI procedure, international schools.

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Cantonal note

Lump-sum taxation — Canton of Valais

Verbier, Crans-Montana, Sion — most accessible canton in French-speaking Switzerland at CHF 250,000.

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Cantonal note

Lump-sum taxation — Canton of Zug

Family office hub — CHF 750,000 floor, lowest corporate tax rate in Switzerland (~11.8%).

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Continental arbitrage

Swiss lump-sum vs Italian Art. 24-bis TUIR

Side-by-side comparison: Italy at €300,000 nominal cap (2026 finance bill) vs Switzerland's living-expense base.

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First meeting

Switzerland — a file to structure with the Firm

First confidential exchange in Geneva to frame your Swiss project: eligibility audit, cantonal choice (Vaud, Valais, Zug, Geneva, Ticino), costed projection including the Kontrollrechnung, ruling negotiation with the cantonal administration, securing the French exit.

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Analysis by Bensaid Avocats SA, Geneva. Last editorial update: 1 June 2026. Indicative content, not personalised tax advice. The Firm conducts a tailored assessment of each situation.