Switzerland

Lump-sum taxation in Switzerland 

For foreign nationals – who take residence in Switzerland for the first time or after ten years of absence, and who are not employed here – taxation according to expenditure can be recommended. This so-called lump-sum taxation has become under pressure in other cantons and on the federal level since it has been abolished by a popular initiative in the Canton of Zurich.

 

From a national perspective, a popular initiative aiming at the abolishment of the taxation according to expenses was launched in March 2011. On 19 October 2012, 103,000 authenticated signatures for the initiative were handed over to the Federal Chancellery. A popular vote is expected in 2014, after the approval by the Federal Chancellery.


The following map gives you an overview of the current situation:

∎  No initiative has been launched or realized
∎  Taxation according to expenses retained, but under tightened conditions
∎ Taxation according to expenses abolished
∎ Initiative realized, popular vote pending

(March 2013)

 
 

Recent developments in lump-sum taxation

New regulations in Social Security

 

With effect from 1 January 2012, among other things higher Social Security contribution rates are applied to non-employed persons. People who are taxed according to expenditure classify as non-employed in Switzerland and are thus directly affected by the increase in the contribution burden.

 

In the case of a foreign working person benefiting from lump-sum taxation in Switzerland, a general exemption from the obligation to contribute to the Swiss Social Security contributions can be applied under certain circumstances.

 

The Federal Council and the Conference of the Cantonal Finance Directors want to promote the acceptance of lump-sum taxation

 

Furthermore, they suggest the following increase of conditions on federal and cantonal level:

  • For the direct federal tax and cantonal tax a minimum limit for the global effort should be defined as seven times the rental cost / rental value or three times the price for board and lodging.
  • For federal taxation a minimum assessment base of CHF 400,000 should be set. The cantons should also specify a minimum amount, but are free to define its height.
  • The cantons will be committed to taking account of the wealth tax for lump-sum taxation.
  • For old cases, a transitional period of 5 years should apply.

Frank Lampert

Frank Lampert

Head of International Private Client Services Switzerland & Partner, Tax

+41 58 249 49 84

flampert@kpmg.com

International Private Client Services

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