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 in Switzerland – taxation according to expenditure can be recommended. The lump-sum taxation allows Switzerland to position itself in international tax competition as an interesting residence for wealthy private individuals, and provide competitive conditions as offered to wealthy mobile private individuals in countries such as the UK, Liechtenstein or Austria where wealthy private individuals find similar offerings.

Persons taxed on expenditure may not work in Switzerland. Since it is very difficult for the authorities to find out the global income or assets of such a person, tax is calculated based on living costs.

 

As of the end of 2012 5,634 persons were profiting from lump-sum taxation, the majority of them living in the cantons Geneva, Wallis and Ticino.

 

Across all three state levels (federal, cantons and municipalities), persons taxed on expenditure paid a total tax revenue of approx. 700 million Swiss francs in the year 2012 (without social contributions). The average tax revenue per person benefiting from lump-sum taxation was in 2012 approximately 120,000 Swiss francs. In addition to the tax revenues, the federal tax authorities estimate that 20’000 to 30’000 jobs are directly or indirectly connected to the lump-sum taxation. Especially structurally fragile regions benefit from lump-sum taxation and the overall economic profit may not be considered as insignificant.

 

The following map gives you an overview of the current situation. Click on the cantons to learn more:

amMap example

Canton: Persons benefiting from lump-sum taxation on 31.12.12 / Total tax revenue

Since the cantons of Appenzell Ausser-Rhoden, Basel-Surrounding area and Basel-City decided to abolish the lump-sum taxation in 2012, these cantons still have lump-sum taxation revenues in the 2012 tax year.

 

Source: KPMG 2014, Data from the Conference of Cantonal Financial Directors in 2013

Status: October 2014

 

 

 Download map as PDF 

 

In the light of the spurred public discussion the latest developments on the legal level and the practical application have lead to a tightening of the lump-sum system. The tightening finally lead to an increased tax burden for the lump-sum taxed persons in Switzerland but also professes the maintenance of this tax system. At the same time with the tightened measures, the public initiative on the abolishment of the lump-sum tax system was declared valid.

 

On 30 November 2014, Swiss voters will decide on the abolishment of the lump-sum taxation.

Frank Lampert

Frank Lampert

Partner, Head of Office in Central Switzerland, Head of International Private Client Services Switzerland, Tax

+41 58 249 49 84

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