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Moving to Switzerland from the UK after non-dom

Leaving the UK after the 6 April 2025 non-dom changes: FIG regime, TRF rates, the IHT tail, Swiss permit routes for UK nationals and lump-sum taxation.

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Lausanne at golden hour
Lausanne, Vaud

Since 6 April 2025 the UK taxes people on residence, not domicile: the remittance basis is gone, newcomers get a four-year foreign income and gains (FIG) regime, and inheritance tax follows long-term residence with a tail of up to ten years after you leave. For UK nationals, Switzerland remains open to people who do not need to work here, but since 1 January 2021 the way in is the Swiss third-country route, usually a permit based on cantonal fiscal interest paired with lump-sum taxation, or a retiree permit from age 55.

Key facts (as of September 2026)

TopicWhat applies
UK remittance basisAbolished from 6 April 2025; 2024-25 was the last year it could be claimed
UK FIG regimeUp to 4 tax years of exemption for arrivals after 10 consecutive years of non-residence
Temporary Repatriation Facility12% for 2025-26 and 2026-27, 15% for 2027-28
UK inheritance taxLong-term resident = UK resident in at least 10 of the last 20 tax years; tail of 3–10 years after leaving
UK nationals in SwitzerlandThird-country (AIG) rules since 1 January 2021, unless covered by the Citizens' Rights Agreement
Swiss lump sum, federalMinimum base CHF 435,000 for tax year 2026
Modified lump sumThe UK is not on the ESTV list of treaties that require it

What changed in the UK on 6 April 2025

The remittance basis, which let non-domiciled residents leave foreign income and gains outside UK tax as long as they were not brought in, was abolished. The 2024-25 tax year was the last in which it could be claimed.

In its place, 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 is not free: it costs the personal allowance and the capital gains tax annual exempt amount. For most people reading this, the FIG regime matters less on the way out than it would on a future return, but it is worth knowing what the new starting line looks like.

Two transitional measures are relevant if you used the remittance basis before:

  • Temporary Repatriation Facility (TRF). Former remittance-basis users can designate foreign income and gains that arose before 6 April 2025 and pay a flat charge: 12% in 2025-26 and 2026-27, 15% in 2027-28.
  • Rebasing. Eligible former remittance users can rebase foreign assets to their value on 5 April 2019.

Whether the TRF or rebasing is useful to you, and when, is a UK question. We would always suggest settling it with your UK adviser before the Swiss side is finalised, because the order of events can matter.

The inheritance tax tail

Inheritance tax now depends on being a long-term UK resident, meaning UK resident in at least 10 of the last 20 tax years. Leaving the UK does not end that status at once. A tail keeps you within UK inheritance tax for a number of years after departure:

Years of UK residence (of the last 20)Indicative tail after leaving
10 to 133 years
144 years
155 years
166 years
177 years
188 years
199 years
2010 years (maximum)

The table applies the gov.uk rule (three years for 10 to 13 years of residence, plus one year for each additional year, up to ten). Confirm your own count with your UK adviser.

On the Swiss side, inheritance and gift taxes are cantonal only; there is no federal inheritance tax. A surviving spouse or registered partner is exempt in every canton, and direct descendants are exempt in most. Schwyz and Obwalden levy neither inheritance nor gift tax. One point matters for lump-sum taxpayers in particular: in Geneva, the spouse and descendant exemptions do not apply if the deceased or donor was taxed on a lump sum in one of the last three final assessments. During the UK tail, both systems can be relevant at the same time, so estate planning needs both sides at the table.

Swiss residence routes for UK nationals

If you were admitted to Switzerland before 1 January 2021, you keep the rights you acquired then. Everyone else is treated as a non-EU/EFTA national under the Foreign Nationals and Integration Act (AIG). For people who will not work here, there are two routes.

Retiree routeFiscal-interest route
Age55 or overNo minimum age
Key conditionSpecial personal ties to SwitzerlandSignificant cantonal fiscal interest
WorkNone, in Switzerland or abroad (managing your own assets is fine)Only abroad, apart from managing your own assets
Who decidesCanton, with mandatory SEM approvalCanton, with mandatory SEM approval

The retiree route needs financial means above the level of Swiss supplementary benefits, reliably available for life, and ties to Switzerland itself: long or repeated earlier stays, close relatives here, or Swiss ancestry. Owning property or having business ties is not enough on its own.

The fiscal-interest route is the one most former non-doms consider. You must move your centre of life to Switzerland and spend most of your time here. The canton weighs its fiscal interest, and the provision leaves it wide discretion. A few cantons publish figures:

  • Geneva states that the major fiscal interest amounts to an expenditure base of CHF 750,000 for third-country nationals.
  • Vaud publishes no amount, but requires a copy of your signed lump-sum agreement with the cantonal tax administration as part of the permit file.
  • Zurich has no lump sum; its guideline refers to an annual tax of about CHF 1 million, confirmed by the tax authority, plus close ties to the canton.

Other cantons do not publish a threshold, so the figure is agreed case by case. Owning Swiss property gives no right to a permit on any route.

Lump-sum taxation for former non-doms

Lump-sum taxation (also called taxation according to expenditure, forfait fiscal or Pauschalbesteuerung) taxes you on your worldwide annual living costs rather than on your income and wealth. It is open to people who are not Swiss nationals, who become fully tax-liable in Switzerland for the first time or after at least ten years away, and who carry out no gainful activity in Switzerland. Both spouses must meet every condition.

For the federal tax, the base is your worldwide living costs, but at least the highest of:

  • CHF 435,000 (tax year 2026);
  • seven times the annual rent or rental value of your home;
  • three times the annual price of board and lodging, if you live in a hotel or pension;
  • a control calculation: ordinary tax on the gross amount of Swiss-source items such as Swiss property, Swiss capital, Swiss pensions and any foreign income for which you claim treaty relief.

Cantons set their own minimum for cantonal and communal tax, and each handles wealth tax differently. A few examples for 2026: Geneva CHF 426,357 with a 10% surcharge in place of wealth tax, Vaud CHF 415,000 including a surcharge for wealth, Valais CHF 250,000, Zug CHF 500,000 and Schwyz CHF 600,000. Zurich, Schaffhausen, Appenzell Ausserrhoden and Basel-Stadt have abolished the regime, and Basel-Landschaft only allows it for the arrival year.

The UK is not on the ESTV list of treaties (Belgium, Germany, Italy, Norway, Canada, Austria, USA) where claiming treaty relief forces a modified lump sum. That said, if part of your portfolio is invested in one of those countries and you want treaty relief there, the modified rules can still reach you. Any UK-specific treaty point should be confirmed in the ruling.

Outside the lump sum, it helps to know that capital gains on private movable assets such as securities and art are tax-free in Switzerland at federal and cantonal level, and that wealth tax is cantonal only.

A practical timeline, without promises

No official processing time is published for the fiscal-interest route, and every canton works at its own pace. What we can describe is the order in which things usually happen:

  1. Settle the UK side first. Your residence position on departure, the TRF, rebasing and your inheritance tax tail. These shape what you bring and how.
  2. Shortlist cantons. Compare minimum bases, wealth treatment, inheritance rules, language, schools and property options.
  3. Agree the lump sum. The amount is set with the cantonal tax authority before or on arrival. In Geneva you propose an amount with a lifestyle form; in Vaud the signed agreement is part of the permit file.
  4. File the permit application. The canton reviews it, indicates its intention to approve, then sends it to SEM, which may refuse, limit or add conditions.
  5. Arrive and register. Register with your commune within 14 days of entry and take out Swiss health insurance within three months of registering.
  6. Settle in. As a non-employed resident you pay AHV/AVS contributions based on wealth and pension income (CHF 530 to CHF 26,500 a year in 2026). A Swiss driving licence is needed after 12 months without a break of more than three months abroad, and a car you have used for at least six months can come in duty-free as relocation goods.

Common pitfalls

  • Keeping a role in Switzerland. A paid board seat or any work carried out here, even if paid abroad, rules out the lump sum.
  • Overlooking your spouse. If one spouse works in Switzerland or becomes Swiss, both lose the regime.
  • Assuming dual nationality is fine. Swiss dual nationals count as Swiss and cannot use the lump sum.
  • Choosing a canton for its name. Zurich is a wonderful place to live, but there is no lump sum there.
  • Treating property as a visa. Buying a home does not give you a permit.

How we help

We map your UK and Swiss positions side by side, help you choose a canton, prepare the lump-sum proposal and permit file, and stay with you through arrival. On the tax side we work with our tax partners. Read more on our UK page, our lump-sum taxation service and why a tax ruling before moving matters. If you are still weighing destinations, see Switzerland vs Italy, the UAE and Monaco, or start with our eligibility check.

This guide is general information as of 30 September 2026 and is not tax or legal advice; your own situation needs a cantonal ruling and professional advice in both countries.

Official sources

  1. HMRC — Technical note: changes to the taxation of non-UK domiciled individuals
  2. HMRC — HS266 Foreign income and gains (FIG) regime (2026)
  3. HMRC — RDRM73400 Temporary Repatriation Facility
  4. gov.uk — Inheritance tax if you're a long-term UK resident
  5. SEM — Weisungen AIG (status 15 June 2026)
  6. Fedlex — art. 14 DBG (lump-sum taxation)
  7. ESTV — Circular 44 (lump-sum taxation)
  8. ESTV — Rundschreiben 2-215-D-2025 (2026 indexation)
  9. EFD — Lump-sum taxation
  10. Canton of Geneva — Calcul des impôts pour les ressortissants de pays tiers
  11. Canton of Vaud — Séjour en raison d'intérêts publics majeurs
  12. ESTV — Geltende Steuern (legal status 1 January 2026)
  13. AHV/IV — Leaflet 2.03 contributions for non-employed persons (2026)

Frequently asked questions

Can UK citizens move to Switzerland without working after Brexit?

Yes, but since 1 January 2021 UK nationals not covered by the Citizens' Rights Agreement apply under Swiss third-country rules. The usual non-working routes are the retiree permit (from age 55, with special ties to Switzerland) and a permit based on significant cantonal fiscal interests. The canton decides and SEM must approve.

Does UK inheritance tax stop when I move to Switzerland?

Not immediately. Since 6 April 2025 UK inheritance tax is residence-based. If you were UK resident for at least 10 of the last 20 tax years, a tail of 3 to 10 years applies after you leave, depending on how long you were resident.

What is the minimum Swiss lump-sum tax base in 2026?

For the federal tax the minimum base is CHF 435,000 for tax year 2026. Cantons set their own minimum for cantonal and communal tax, and the base is always at least seven times the annual rent or rental value of your home.

Is the UK on the list of treaties requiring a modified lump sum?

No. The ESTV list covers Belgium, Germany, Italy, Norway, Canada, Austria and the USA. Other treaty questions affecting UK income should be checked when you agree your lump sum with the canton.

Can I use the Swiss lump sum in Zurich?

No. Zurich abolished lump-sum taxation with effect from 1 January 2010. Schaffhausen, Appenzell Ausserrhoden and Basel-Stadt have also abolished it, and Basel-Landschaft only allows it for the arrival year.

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