Switzerland lump-sum taxation (Pauschalbesteuerung / taxation selon la dépense): for non-working foreign nationals resident in Switzerland. Tax based on living expenses rather than actual income.
Source-cited draft.Written from sources but not reviewed by a licensed practitioner, so it may be incomplete or wrong. General reference only; don't file or take a position on it without professional review.
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Use OpenAccountants for CH Lump Sum in Switzerland.
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Every figure is drawn from this Tax Guide and cited to its source.
Condition 1: Swiss resident
Swiss resident (must have permit — B or C permit acceptable)
Condition 2: Not a Swiss citizen
Not a Swiss citizen
Condition 3: Not gainfully employed in Switzerland
Not gainfully employed in Switzerland — no salary, no business income from Switzerland. Investment income and foreign business income are fine.
Condition 4: First time establishing Swiss residence
First time establishing Swiss residence (or returning after 10+ years absence)
Spouses/partners filing together
Spouses/partners must both meet the conditions if filing together.
Tax base calculation
Tax base = MAX of: (a) 7 × annual rent (or rental value if owner-occupied) (b) Actual living expenses (worldwide) if higher (c) Cantonal minimum amounts (vary by canton — e.g. CHF 400,000 in some)
Cantonal minimum tax bases (examples)
Some cantons have set explicit minimum tax bases (e.g. Valais: CHF 250,000; Vaud: CHF 250,000; Geneva: CHF 400,000; Ticino: CHF 500,000).
Federal minimum tax base
CHF 451,200
Applicable tax rate on lump-sum base
The agreed tax base is taxed at ordinary Swiss income tax rates (federal + cantonal + communal). No special reduced rate — the benefit is the smaller base.
Effective all-in rates on typical lump-sum bases
15%–35%
Treaty benefits limitation
Switzerland's extensive DTA network is NOT fully available to lump-sum taxpayers. Treaty reduced withholding rates require that the taxpayer is subject to Swiss tax on the specific income in question. For most DTAs, treaty benefits are only available on income up to the tax base amount.
No CGT on private moveable assets
Switzerland does not tax capital gains on private moveable assets (shares, bonds, funds) for private investors — lump-sum or not. This is a key attraction.
CGT on real property
Capital gains on real property are taxed (by cantons) — even under lump-sum. See `ch-cantonal-tax`.
Rendered from the canonical facts model. General reference only — confirm with a qualified professional before acting.
Quick reference (DBG Art. 14; StHG Art. 6)
| Item | Value |
|---|---|
| Official name | Pauschalbesteuerung (DE) / Imposition d'après la dépense (FR) |
| Available to | Foreign nationals who are NOT gainfully employed in Switzerland |
| Tax base | Annual living expenses (not actual income) |
| Minimum tax base | 7× annual rent or rental value of Swiss residence |
| Cantons | Available in most cantons (a few abolished it: ZH, SH, AR, AI, BL, BS) |
| Legislation | DBG Art. 14; StHG Art. 6 |
Practical impact: lump-sum taxpayers may not reclaim withholding tax on foreign dividends/interest above certain amounts. Specific to each treaty — requires treaty-by-treaty analysis.
ch-cantonal-tax.Working paper only. Lump-sum negotiations are done directly with the cantonal tax authority (Steueramt) and involve detailed negotiation. The specific canton chosen affects the outcome significantly. Engage a qualified Swiss tax adviser (Treuhänder/fiduciaire) before establishing Swiss residence.
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Other Switzerland computations in the OpenAccountants Tax Library.