Switzerland for UK private clients after the non-dom changes: an adviser briefing

Since 6 April 2025 the UK taxes on residence rather than domicile: the remittance basis has gone, and long-term UK residents stay within inheritance tax for up to ten years after leaving. For UK nationals, Switzerland is open to clients who do not need to work here, but since 1 January 2021 they apply as third-country nationals, usually through the retiree route or a permit based on cantonal fiscal interests, often paired with lump-sum taxation. This briefing sets out the facts on both sides and the sequencing questions worth raising early.

Key facts (as of September 2026)

The UK side, as it now stands

We do not advise on UK tax. The points below are the verified UK facts that shape the Swiss timetable, so that both sides of the move work from the same page.

• Remittance basis abolished. From 6 April 2025 the remittance basis no longer exists. The 2024-25 tax year was the last in which it could be claimed.
• Four-year FIG regime. People who become UK resident after 10 consecutive tax years of non-residence can opt, year by year, to exempt foreign income and gains for up to four tax years. The claim costs the personal allowance and the capital gains tax annual exempt amount. It matters mainly if a client might return to the UK one day.
• Temporary Repatriation Facility (TRF). Former remittance-basis users can designate pre-6 April 2025 foreign income and gains at 12% for 2025-26 and 2026-27, and 15% for 2027-28.
• Rebasing. Eligible former remittance-basis users can rebase foreign assets to 5 April 2019.

Inheritance tax: long-term residence and the tail

Inheritance tax now follows residence. A "long-term UK resident" is someone who has been UK resident in at least 10 of the last 20 tax years. After leaving, the exposure continues for a tail whose length depends on the years of residence:

For a client who has lived in the UK most of their adult life, a ten-year tail is the realistic planning horizon. How estate plans, trusts and lifetime gifts are handled during that period is a question for UK counsel. On the Swiss side, inheritance and gift taxes are cantonal: surviving spouses are exempt everywhere and direct descendants in most cantons, Schwyz and Obwalden levy neither tax, and in Geneva the spouse and descendant exemption does not apply where the deceased or donor was lump-sum taxed in one of the last three final assessments. See our guide to inheritance and gift tax.

Swiss residence routes for UK nationals

Since 1 January 2021, UK nationals not covered by the Citizens' Rights Agreement are subject to the ordinary Swiss rules for third-country nationals. Clients admitted before that date keep their acquired rights. The UK quota for 2026 (2,100 B and 1,400 L permits) concerns gainful activity only; it does not apply to clients who come without working.

Retiree route (art. 28 AIG). Cumulative conditions: at least 55 years old, special personal ties to Switzerland (for example long or repeated earlier stays, close relatives here, Swiss ancestry), sufficient means reliably available for life, and no gainful activity in Switzerland or abroad other than managing one's own assets. Owning property or having business ties is not enough on its own. The centre of life must be in Switzerland.

Important cantonal fiscal interests (art. 30 para. 1 let. b AIG, art. 32 VZAE). The client moves the centre of life to Switzerland and spends most of their time here. Gainful activity is allowed only abroad, apart from managing one's own assets. This is a "may" provision with wide discretion. The canton signals its intention to approve, then SEM decides and may refuse, limit or attach conditions. A few cantons publish benchmarks: Geneva states its major fiscal interest at an expenditure base of CHF 750,000 for third-country nationals; Zurich, which has no lump-sum regime, considers an annual tax of about CHF 1 million sufficient, confirmed by the tax authority; Vaud requires a copy of the lump-sum agreement with the cantonal tax authority as part of the file. Most cantons publish no figure.

For the wider picture, see moving from the UK after non-dom and our residence permit service.

Lump-sum taxation: the basics

Lump-sum taxation (imposition d'après la dépense) taxes a client on worldwide annual living costs rather than on income and wealth. The conditions are federal:

• the client is not Swiss (a Swiss dual national is excluded);
• they become fully taxable in Switzerland for the first time or after at least 10 years' absence;
• they carry out no gainful activity in Switzerland, including board seats;
• both spouses meet all conditions.

For the federal tax, the base is the highest of: actual worldwide living costs, CHF 435,000 for 2026, 7× the annual rent or rental value of the home, 3× the annual board-and-lodging price, and the control calculation. That control calculation adds up, gross, Swiss real estate and its income, movable property and capital invested in Switzerland and its income, Swiss-source pensions, and foreign income for which treaty relief is claimed. CHF 435,000 is a minimum base, not a tax amount.

Cantons set their own minimum base for cantonal and communal tax, and treat wealth tax differently:

Source: ESTV cantonal fact sheets, February 2026. Schaffhausen, Appenzell Ausserrhoden and Basel-Stadt have also abolished the regime, and Basel-Landschaft allows it for the arrival year only. See lump-sum taxation by canton.

Treaty point. Under the treaties with Belgium, Germany, Italy, Norway, Canada, Austria and the USA, treaty relief requires a "modified" lump sum that taxes all income from that state. The UK is not on that list. Whether any other UK treaty point affects a given client should be checked with the canton when the lump sum is agreed.

Sequencing questions to raise early

The order of steps is where most of the value lies. These are the questions we usually work through with the UK adviser:

1. When does Swiss tax residence start? Swiss law uses domicile (living here with the intention to stay) or a stay of 90 days without gainful activity (30 days with it), not a 183-day rule. The arrival date should be planned against the UK departure date.
2. Which UK steps must happen before departure? TRF designations, any disposals, and the handling of trusts and gifts are UK decisions; the Swiss file should reflect the position after them.
3. Is lump-sum taxation the right choice? It depends on living costs, the canton and where income arises. We compare it with ordinary taxation before a ruling is requested.
4. Ruling first, permit second? The tax side and the permit are closely linked: Vaud lists the signed lump-sum agreement as a required permit document, and Geneva expects the lump-sum request together with the migration procedure.
5. Any Swiss activity? Board seats or advisory roles in Switzerland rule out the lump sum for both spouses.
6. Rent or buy? For a non-EU B-permit holder, a main residence at the actual domicile can be bought without a Lex Koller permit; a holiday home is a different matter. The rent or rental value also sets the 7× floor.

What to prepare

For a first assessment, no names are needed. When the file moves forward, the canton will usually ask for:

• an explanation of the client's situation and a confirmation of no gainful activity in Switzerland;
• a proposed lump-sum amount supported by a budget of worldwide living costs (Geneva uses a lifestyle form);
• a copy of the lease or a property valuation;
• for the retiree route, evidence of the ties to Switzerland and of lifelong means.

How we help

We handle the Swiss side, from the route assessment and ruling request to the permit file and arrival, and keep you informed at each step while the client relationship stays with you. See what we handle and what stays with you, or send an anonymous profile through the adviser introduction form.

This briefing is general information as of 30 September 2026. It is not UK or Swiss tax advice; each client's situation needs its own assessment and, where relevant, a tax ruling.