Switzerland for German clients: a briefing for their advisers

German clients 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. A client who wants lump-sum taxation and keeps income from Germany will almost always end up with the modified lump sum: treaty benefits are only granted if all German income is taxed in Switzerland as under ordinary taxation. On the German side, exit tax under § 6 AStG is usually the first item in the plan.

This briefing is for tax advisers (Steuerberater), lawyers and wealth managers helping German clients move to Switzerland. It sets out what is established on the Swiss side and shows where your analysis sets the pace.

Key facts for advisers (September 2026)

Which clients this fits

Lump-sum taxation requires that the person is not Swiss, becomes subject to unlimited Swiss tax liability for the first time or after at least ten years' absence, and carries out no gainful activity in Switzerland. A few points rule it out straight away:

• Dual nationality. German-Swiss dual nationals count as Swiss and are 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 works in Switzerland or becomes Swiss, the couple loses the lump sum for the whole period.

A client who does not qualify can still move under free movement and is then taxed under the ordinary rules. Once someone has switched to ordinary taxation, they generally cannot go back.

The residence route: free movement without gainful activity

For German nationals 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. After registering with the commune, the client has three months to join Swiss compulsory health insurance (KVG).

The EU/EFTA B permit for non-employed people is normally issued for five years and can be withdrawn if the means or insurance fall away. Germany has a settlement agreement with Switzerland, so there is a right to a C permit after five years. Details are in our guide to the EU B permit without work.

Without gainful activity, AHV contributions are due on wealth plus 20 times annual pension income, between CHF 530 and CHF 26,500 a year in 2026, until age 65. Once domiciled in Switzerland, the client is no longer subject to Lex Koller when buying a home.

Lump-sum taxation: the base and the control calculation

The tax is based on the worldwide living costs of the person and their dependants. For direct federal tax the base is at least the highest of (art. 14 para. 3 DBG):

• CHF 435,000 for 2026 (CHF 434,700 in 2025);
• 7 times the annual rent or rental value;
• 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 treaty relief is claimed.

CHF 435,000 is a minimum base, not a minimum tax; the ordinary tariff is applied, with no deductions. At cantonal level the control calculation also includes Swiss wealth items. Cantons set their own minimums; in German-speaking Switzerland, for example:

Source: ESTV cantonal fact sheets, February 2026. The other cantons are in our overview of lump-sum taxation by canton.

The modified lump sum for German income

Lump-sum taxpayers can in principle claim treaty relief, for example reduced foreign withholding tax; they must declare it, and the relieved income enters the control calculation. The treaty with Germany goes a step further. Germany is one of seven states (with Austria, Belgium, Canada, Italy, Norway and the USA) for which the ESTV's Circular 44 provides:

• treaty benefits only if all income from Germany is taxed in Switzerland as under ordinary taxation;
• that income is added to the base and taxed at the rate for total income;
• if full data is not provided, the maximum rate applies;
• in return, under these seven treaties lump-sum taxpayers have access to the flat-rate foreign tax credit, which is otherwise closed to them.

Cantons ask about it directly; Uri's checklist, for instance, asks whether treaty relief is claimed from Germany or one of the other six states. For clients with German rental income, dividends or pensions, a comparison between the modified lump sum and ordinary taxation before the ruling is well worth doing. Details in our guide to the modified lump sum.

If Germany and Switzerland both claim the person as resident, the treaty's tie-breaker rules (permanent home, centre of vital interests, habitual abode, nationality) decide.

Exit tax under § 6 AStG

For clients with shareholdings, German exit tax is usually where planning starts:

• Who: people with unlimited German tax liability for at least 7 of the last 12 years.
• What: shares within § 17 EStG, i.e. holdings of at least 1%.
• Effect: leaving is treated as a sale at fair value.
• Payment: in seven equal annual instalments, usually against security.
• Return: relief is possible, under conditions, if the person becomes subject to unlimited German tax liability again within seven years.

Valuation, security and timing of departure sit with you. Other consequences under German law, such as extended limited tax liability or German inheritance tax after the move, are not something we review; they belong on your checklist. On the Swiss side: gains on private movable assets such as securities are tax-free; gains on real estate are subject to a separate cantonal tax.

Inheritance and wealth on the Swiss side

Wealth tax is purely cantonal; Lucerne, Uri, Schwyz, Obwalden, Nidwalden, Glarus, Appenzell Innerrhoden, St. Gallen and Thurgau use flat rates. Inheritance and gift taxes are cantonal too:

• Spouses are exempt in every canton, direct descendants in most.
• Schwyz and Obwalden levy neither inheritance nor gift tax.
• Lucerne has no gift tax but adds back gifts made in the five years before death; only communes may tax descendants (exemption limit CHF 100,000).
• Appenzell Innerrhoden gives descendants a CHF 300,000 deduction.

More in our guide to inheritance and gift tax.

Coordinating the process with the German adviser

1. German analysis first: § 6 AStG, other departure consequences, treatment of income staying in Germany. This often sets the departure date.
2. Comparison of the modified lump sum against ordinary taxation, with full data on German income.
3. Canton choice and ruling with the cantonal tax authority on concrete facts, including a living-costs budget.
4. Arrival: registration with the commune, EU/EFTA B permit, health insurance within three months.
5. Ongoing: annual lump-sum return; changes must be reported without being asked, and the canton checks the conditions every year.

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 stays with you. For a first conversation, without names if you prefer, visit our adviser page or introduce a client. For the client, our guide to moving to Switzerland from Germany 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 German adviser.