Switzerland for French clients: a briefing for their advisers

A French client can move to Switzerland without working under the free movement of persons: they need sufficient financial means and comprehensive health and accident insurance, with no quota and no minimum investment. Swiss lump-sum taxation can be combined with this EU permit, but the Swiss federal tax administration (ESTV) lists the France–Switzerland treaty among those with special rules for lump-sum taxpayers, so treaty treatment should be confirmed in a ruling, with you involved. On the French side, exit tax and succession questions usually set the timetable.

This briefing is for French wealth managers (CGP), notaires and tax lawyers helping a client move to Switzerland. It sets out what is established on the Swiss side and flags what belongs to your own analysis.

Key facts for advisers (September 2026)

Which clients this fits

The EU permit plus lump sum suits a client who stops all gainful activity in Switzerland and has not had unlimited Swiss tax liability in the last ten years. A few points rule the lump sum out straight away:

• Swiss nationality. A French-Swiss dual national counts as Swiss and is excluded.
• Activity in Switzerland. Any main or side occupation carried out in Switzerland counts, even if paid from abroad; Circular 44 names board members among others.
• The spouse. Both spouses must meet every condition. If one becomes Swiss or works in Switzerland, the couple loses the lump sum for the whole period.

A client who does not qualify can still move under free movement, but will be taxed under the ordinary rules.

The residence route: free movement without gainful activity

For a French national there is no minimum age, no need to prove special ties and no fiscal interest to show. Two conditions are enough:

• Sufficient financial means, meaning above the level at which social assistance could be claimed; for a retiree, above the threshold for supplementary benefits.
• Comprehensive health and accident insurance. Once settled, the client must join Swiss compulsory health insurance (KVG) within three months of registering with the commune.

The EU/EFTA B permit for non-employed people is normally issued for five years and can be withdrawn if the means or insurance fall away. Because France has a settlement agreement with Switzerland, the client has a right to a C permit after five years. Our guide to the EU B permit without work covers the file.

Two practical points to pass on: without gainful activity the client pays AHV contributions based on wealth plus 20 times annual pension income (CHF 530 to CHF 26,500 a year in 2026), until age 65. And once domiciled in Switzerland, they are no longer subject to Lex Koller when buying a home.

Lump-sum taxation: the 2026 figures

Lump-sum taxation (art. 14 DBG) taxes the worldwide living costs of the client and their dependants, in Switzerland and abroad, instead of income and wealth. For direct federal tax the base is at least the highest of:

• CHF 435,000 for 2026 (CHF 434,700 in 2025);
• 7 times the annual rent or rental value of the home;
• 3 times the annual board-and-lodging price, for someone living in a hotel;
• the control calculation: the gross total of Swiss-source income (real estate, capital invested in Switzerland, Swiss pensions) and foreign income for which the client claims treaty relief.

A useful point for your conversations: CHF 435,000 is a minimum base, not a minimum tax. The ordinary tariff applies to it, with no deductions. Each canton sets its own minimum for cantonal and communal tax; in French-speaking Switzerland:

Source: ESTV cantonal fact sheets, February 2026. The lump sum no longer exists in Zurich, Schaffhausen, Appenzell Ausserrhoden and Basel-Stadt, and Basel-Landschaft allows it only for the arrival tax year. The canton checks the conditions every year, and a client who gives up the lump sum generally cannot return to it. The full mechanism is explained in how lump-sum tax is calculated.

The France–Switzerland treaty: what is established and what to confirm

This is where we recommend the most care. What official sources support:

• A lump-sum taxpayer can claim Swiss treaty relief, for example reduced foreign withholding tax. It must be declared, and the income concerned then enters the control calculation.
• Seven treaties (Austria, Belgium, Canada, Germany, Italy, Norway, USA) require a modified lump sum. Circular 44 also names France among treaties with special rules.
• Outside those seven treaties, lump-sum taxpayers generally have no right to the flat-rate foreign tax credit.
• If France and Switzerland both treat the client as resident, the treaty's tie-breaker rules (permanent home, centre of vital interests, habitual abode, nationality) decide.

We have not verified the exact content of the French special rule on an official source, so we do not summarise it. Our recommendation is simple: if the client keeps income, real estate or pensions in France, have the treaty treatment of their Swiss residence confirmed in the cantonal ruling and checked on your side before departure. See also our guide to the modified lump sum and tax treaties.

Exit tax: article 167 bis CGI

French exit tax targets unrealised gains on certain holdings when tax domicile leaves France:

• tax domicile in France for at least 6 of the last 10 years;
• holdings of at least 50% of a company's profits, or worth more than €800,000;
• automatic deferral for moves to an EU state or a state with an adequate assistance convention with France;
• cancellation if the shares are still held 2 years after departure, or 5 years above €2.57 million.

We have not confirmed on an official source whether a move to Switzerland qualifies for automatic deferral. That is for you to settle for the client, ideally before the Swiss arrival date is fixed.

Inheritance and gifts: what we can say on the Swiss side

Switzerland has no federal inheritance tax; the cantons tax inheritances and gifts. A surviving spouse is exempt everywhere and direct descendants are exempt in most cantons. Exceptions that matter for a French family:

• Vaud taxes descendants above CHF 1 million, with a tapering deduction up to CHF 2 million; Neuchâtel above a CHF 50,000 deduction.
• Geneva removes the spouse and descendant exemptions if the deceased or donor was taxed on a lump sum in one of the last three final assessments. This often weighs in the choice between Geneva and Vaud.
• Schwyz and Obwalden levy neither inheritance nor gift tax.
• Movable assets are taxed in the canton of last domicile, real estate where it is located.

The initiative for a federal 50% inheritance tax above CHF 50 million was rejected on 30 November 2025. How France taxes an inheritance or gift after the move is entirely for the French notaire's analysis, and we do not cover it here. Our guide to inheritance and gift tax in Switzerland covers the Swiss side.

Coordinating the timetable with the French adviser

In files that go smoothly, the order is almost always the same:

1. French analysis first: exit tax, treaty treatment of income staying in France, succession consequences. This often sets the departure date.
2. Choice of canton based on the profile: lump-sum minimum, wealth tax, inheritance rules.
3. Ruling with the cantonal tax authority on concrete facts. In Geneva, for example, the client proposes a lump-sum amount, with the lease or property valuation and a lifestyle form.
4. Arrival: registration with the commune, EU/EFTA B permit, health insurance within three months.
5. Follow-up: annual lump-sum return and reporting any change of situation without being asked.

Questions to ask the client before a first call

• Do they or their spouse hold Swiss nationality, or plan any activity in Switzerland (including a board seat)?
• Have they been taxed in Switzerland in the last ten years?
• What income stays in France (rent, dividends, pensions)?
• Do they hold participations covered by article 167 bis?
• Which canton, what kind of home, what realistic annual living costs?

How we work with you

We handle the Swiss side, from canton choice to ruling and permit, and keep you informed at each step; the client relationship and your mandates stay with you. For a first conversation, without the client's name if you prefer, visit our adviser page or introduce a client. For the client, our guide to moving to Switzerland from France can be forwarded as it is.

This briefing is general information as of 30 September 2026; each situation needs a cantonal ruling and advice from a French adviser.