Switzerland lump-sum taxation (forfait fiscal): cantons, minimums, who it fits
How Switzerland's lump-sum tax works in 2026: the CHF 435,000 federal floor, the seven-times-rent rule, cantonal choices, and who qualifies.
Switzerland’s lump-sum taxation lets a qualifying foreign national be taxed on their yearly living expenditure rather than on worldwide income and wealth. It is a long-standing, legal regime (also called forfait fiscal or expenditure-based taxation) aimed at wealthy people who move to Switzerland and do not work there. For a mass-affluent mover weighing residence options, it offers a predictable, negotiated tax bill agreed with the canton before arrival, which is why it remains one of Europe’s most-used relocation routes (Federal Department of Finance).
What the regime actually taxes
Lump-sum taxation replaces the ordinary income and wealth tax base with a deemed figure built from your cost of living. Instead of declaring every source of global income, you and the cantonal tax office agree a taxable base derived from your annual expenditure, and ordinary federal, cantonal and communal tax rates are then applied to that base (KPMG Switzerland).
The appeal is certainty. Your worldwide investment returns, foreign business income and overseas assets sit outside the ordinary assessment, so the annual bill is stable and known in advance. Roughly 4,700 people were taxed this way at the end of 2024 on figures reported by the Federal Tax Administration, with the cantons of Vaud, Valais, Geneva, Ticino and Graubünden hosting most of them (KPMG Switzerland).
The federal minimum and how the base is built
The taxable base is the highest of several figures, and a federal floor sets the absolute minimum. Federal law fixes a minimum deemed base that is indexed periodically for cold progression; for 2026 it stands at CHF 435,000, following the cold-progression ordinance effective 1 January 2026 (it was CHF 434,700 before this adjustment) (Taxolution Advisory; KPMG Switzerland). The floor began at CHF 400,000 when the reformed rules took effect in 2016 and has risen with indexation since (Federal Tax Administration).
Above that floor, the housing test usually drives the number. The base must be at least seven times your annual rent, or seven times the rental value of a home you own and occupy; people living in a hotel or on board and lodging use three times that cost instead (KPMG Switzerland). Your final base is then the largest of the housing figure, your actual worldwide living expenses, and the federal or cantonal minimum.
| Component | Rule (federal) |
|---|---|
| Housing (tenant) | 7 × annual rent |
| Housing (owner-occupier) | 7 × rental value of the home |
| Board and lodging (hotel guests) | 3 × the annual cost |
| Federal minimum base, 2026 | CHF 435,000 |
| Final taxable base | The highest of the above |
A second safeguard, the control calculation (Kontrollrechnung), runs alongside. Your lump-sum tax must be at least as high as the ordinary tax that would fall on a defined list of Swiss-source items, such as Swiss real estate, Swiss securities and income for which you claim treaty relief (Taxolution Advisory). This keeps domestic income taxed at normal rates while the regime shelters foreign income.
Cantonal variation, and the cantons that dropped it
Each canton sets its own terms, and five cantons no longer offer the regime. Federal law provides the framework, yet the taxable base for cantonal and communal tax is agreed locally, so both the minimum and the effective rate differ by canton. Five German-speaking cantons have abolished expenditure-based taxation at cantonal level: Zurich, Schaffhausen, Appenzell Ausserrhoden, Basel-Landschaft and Basel-Stadt (Federal Department of Finance). Zurich led the way after a 2009 popular vote, effective from 2010, and the others followed.
Elsewhere the regime is alive and competitive. The French-speaking and Alpine cantons remain the main destinations, with cantonal minimum bases that often track or exceed the federal floor. Practitioners commonly cite figures around CHF 450,000 in Vaud and around CHF 500,000 in Geneva, while several cantons align closely to the CHF 435,000 federal minimum; these cantonal numbers are agreed case by case, so confirm the current threshold with a local advisor before committing (Taxolution Advisory).
The regime also survived a national vote. On 30 November 2014 Swiss voters rejected a federal initiative to abolish lump-sum taxation across the country, by 59.2 per cent, which settled its status for the foreseeable future (swissinfo).
How wealth is taxed under the regime
Lump-sum taxpayers still pay cantonal wealth tax, calculated on a deemed basis. Switzerland levies wealth tax at cantonal and communal level, and the regime does not remove it. Cantons define a deemed wealth base under their own law, frequently as a multiple of the deemed income base; the multiple and any minimum differ from canton to canton (KPMG Switzerland). The practical effect is a wealth-tax charge that is proportionate to the agreed base, so it stays predictable, and the exact figure is worth modelling for your target canton with an advisor.
Who qualifies
Four conditions apply at the same time, and all four must be met. The regime is open only where each of the following holds (KPMG Switzerland; Federal Department of Finance):
- You are not a Swiss citizen. Dual nationals who hold a Swiss passport do not qualify.
- You are taking up Swiss tax residence for the first time, or returning after at least ten years abroad.
- You pursue no gainful activity in Switzerland. Managing your own worldwide assets is accepted; Swiss employment and Swiss directorship fees are not.
- Both spouses meet the conditions where a married couple applies together.
Meeting these gates is only the entry point. A residence permit still has to be secured under the ordinary immigration rules, and non-EU/EFTA nationals in particular often obtain residence in tandem with the tax ruling.
Who it fits
The regime suits internationally mobile people with substantial foreign income who will not work in Switzerland. It tends to work best when your worldwide income comfortably exceeds the deemed base, because the saving grows with the gap between your real income and the agreed figure. Retirees, family-office principals and those living on global investment portfolios are the natural fit; someone whose income is modest relative to the CHF 435,000 floor may pay ordinary tax more cheaply, so the comparison is worth running both ways.
The choice of canton then shapes the outcome, since the minimum base, wealth-tax treatment and communal multiplier all move the final bill. A short, structured comparison of two or three cantons against your income and asset profile usually settles the decision.
If you want the numbers mapped to your own situation, our instant check gives a first read on whether the regime fits, and the sample report shows the advisor-ready detail we prepare before you brief a Swiss tax lawyer.
Frequently asked questions
Who can use Swiss lump-sum taxation? Foreign nationals taking up Swiss residence for the first time, or after ten years away, who do not work in Switzerland. Swiss citizens and dual nationals with a Swiss passport are excluded, and any Swiss employment or directorship ends eligibility (KPMG Switzerland).
How much tax will I actually pay? Ordinary federal, cantonal and communal rates apply to your deemed base, which for 2026 is at least CHF 435,000 at federal level and often higher in practice. The exact bill depends on the canton and commune, so it is agreed with the tax office before you move; confirm the figure with a Swiss advisor (Taxolution Advisory).
Can I still invest while on the regime? Yes for your own private assets, no for Swiss employment. Managing your worldwide portfolio is accepted, while gainful activity carried out in Switzerland, including Swiss directorships, is not permitted under the regime (Federal Department of Finance).
Which cantons offer it, and which have dropped it? Most cantons offer it, led by Vaud, Valais, Geneva, Ticino and Graubünden. Five have abolished it at cantonal level: Zurich, Schaffhausen, Appenzell Ausserrhoden, Basel-Landschaft and Basel-Stadt (Federal Department of Finance).
Sources
- Federal Department of Finance (EFD), “Lump-sum taxation” — accessed 16 July 2026
- Federal Tax Administration (ESTV), direct federal tax tariffs and cold-progression adjustments — accessed 16 July 2026
- KPMG Switzerland, “Swiss lump-sum taxation: eligibility, calculation and updates” — accessed 16 July 2026
- Taxolution Advisory, “Swiss lump-sum taxation 2026” — accessed 16 July 2026
- swissinfo, “No more tax privileges for millionaires” (30 November 2014 vote) — accessed 16 July 2026