Swiss lump-sum taxation in 2026: who qualifies

Swiss lump-sum taxation lets foreign nationals who live in Switzerland but do not work here be taxed on their worldwide living costs instead of their income and wealth. For 2026 the federal tax base is at least CHF 435,000, and each canton that offers the regime sets its own minimum on top of a few fixed tests.

Key facts (as of September 2026)

What is lump-sum taxation?

The regime has several names, which is part of the confusion around it. In English it is usually called lump-sum taxation or taxation according to expenditure. In French it is the forfait fiscal or imposition d'après la dépense; in German, Pauschalbesteuerung or Besteuerung nach dem Aufwand. They all mean the same thing.

Instead of declaring every item of income and wealth each year, you are taxed on a base that reflects how much it costs you and your family to live, wherever that money is spent. The ordinary tax rates are then applied to that base. It is not a flat fee and it is not a negotiated discount: it is a different way of working out the amount on which normal rates are charged.

The rules sit in federal law. Article 14 of the Federal Act on Direct Federal Tax (DBG) covers the federal tax. Article 6 of the Tax Harmonisation Act (StHG) allows each canton to offer the regime for cantonal and communal tax, but does not oblige it to. The Federal Tax Administration (ESTV) explains how it applies in its Circular No. 44 of 24 July 2018. Since 1 January 2021 the current rules apply to everyone, including people who were taxed under the older regime.

Who qualifies for lump-sum taxation?

There are four conditions, and all of them must be met.

• You are not Swiss. Dual nationals who hold Swiss citizenship count as Swiss and are excluded. If you become Swiss later, the regime ends for the whole tax period in which you are naturalised.
• You are arriving for the first time, or after a long absence. The regime is for people who become fully tax resident in Switzerland for the first time, or after at least 10 years abroad. Someone who was taxed on a lump sum before and comes back may use it again, whatever the gap.
• You do not work in Switzerland. Any main or side occupation carried out in Switzerland rules you out, even if you are paid from abroad. The ESTV names artists, scientists, inventors, athletes and board members active in Switzerland as examples. Managing your own assets is fine.
• Your spouse also qualifies. If you are married, both spouses must meet every condition. If one spouse is or becomes Swiss, or starts working in Switzerland, both lose the regime for that whole tax period.

A few practical points follow from these rules. Working abroad is not excluded by the tax rules, but your residence permit may have its own conditions (see below). Retired diplomats or international civil servants who stay on after their posting do not qualify, because they were already resident. And cantons sometimes publish nuances: Uri, for instance, accepts an unpaid board seat that only serves to manage your own assets or is honorary.

One decision is hard to undo. If you give up the lump sum for ordinary taxation, you generally cannot go back to it, so it pays to compare both regimes carefully before the first return.

How is the lump-sum tax base set?

The starting point is your worldwide annual living costs and those of your dependants, in Switzerland and abroad. That includes housing, staff, schooling, travel, cars, boats, aircraft, horses and even the taxes and social-security contributions you pay. No deductions are allowed from the base.

The base can never be lower than the highest of four floors:

1. CHF 435,000 for federal tax in 2026 (indexed to inflation; it was CHF 434,700 in 2025);
2. seven times the annual rent, or the rental value if you own your home;
3. three times the annual price of board and lodging, if you live in a hotel or similar;
4. the result of the control calculation, which checks that the tax is at least what ordinary tax would be on certain Swiss-source and treaty-relieved income.

The rent test and the control calculation are where most of the detail lies, and where most misunderstandings start. We explain both, with simplified illustrations, in how the lump-sum tax is calculated.

The ordinary federal tax rates then apply to the base, without the usual social deductions. Because taxes themselves count as living costs, cantons work out the final figure by grossing up. Geneva publishes worked examples of this method for EU/EFTA and non-EU residents.

Federal and cantonal: two layers

Switzerland taxes income at three levels: federal, cantonal and communal. The federal minimum of CHF 435,000 applies to the federal tax everywhere the regime is used. Cantonal and communal tax follows the canton's own rules, with its own minimum base and its own way of covering wealth tax.

Published cantonal minimums range widely. As of February 2026, the ESTV fact sheets show CHF 200,000 in Jura, CHF 250,000 in Valais and Fribourg, CHF 415,000 in Vaud (including a surcharge for wealth tax), CHF 500,000 in Zug and CHF 647,100 in Lucerne for 2026. Thurgau works differently, with a minimum cantonal and communal tax of CHF 150,000. The full list, with sources, is in our lump-sum taxation by canton table.

Five cantons have stepped away from the regime. The Federal Department of Finance lists Zurich (abolished by vote in 2009, effective 2010), Schaffhausen, Appenzell Ausserrhoden, Basel-Landschaft and Basel-Stadt. Basel-Landschaft still has a provision, but it only runs until the end of the arrival year. Thurgau, St. Gallen, Lucerne and Bern kept the regime but tightened it.

Lump-sum taxation and your residence permit

The tax regime and the right to live in Switzerland are two separate questions, and they are decided by different authorities.

EU and EFTA nationals who do not work can usually obtain a residence permit if they have sufficient financial means and full health and accident insurance. The lump sum can be combined with that permit, as Uri's leaflet notes.

Non-EU nationals (including UK nationals arriving since 2021) have narrower routes. The most common for people using the lump sum is a permit for important public interests, in practice significant cantonal fiscal interests, under art. 30 AIG and art. 32 VZAE. The canton has wide discretion and the State Secretariat for Migration (SEM) must approve each case. Geneva publishes a figure for this: its "major fiscal interest" corresponds to an expenditure base of CHF 750,000 for third-country nationals. Vaud asks for a copy of the lump-sum agreement with its tax administration as part of the permit file. Applicants aged 55 or over who have special personal ties to Switzerland (owning property is not enough) and sufficient means may also use the retiree route, again at the canton's discretion and with SEM approval. Our guide to residence for financially independent non-EU nationals covers these routes in detail.

How do you apply?

You apply to the cantonal tax administration, usually alongside the migration procedure. Geneva, for example, asks for a letter explaining your situation and confirming that you will not work in Switzerland, a proposed lump-sum amount, a copy of the lease or a property valuation, and a lifestyle form. Uri asks for details of your worldwide income and wealth and a living-cost budget.

Most families prefer to settle the amount in writing before they commit to a move. That is what a tax ruling before moving is for.

After arrival, the regime is reviewed every year. You file a specific lump-sum return, the authority checks that the conditions are still met, and you must report any change (a new job, a Swiss passport, a spouse starting work) without being asked.

Treaties and foreign income

Lump-sum taxpayers can still claim relief under Switzerland's double tax treaties, for instance a reduced foreign withholding tax, but they must declare the income concerned, and it then counts in the control calculation. Under the treaties with Belgium, Germany, Italy, Norway, Canada, Austria and the United States, a stricter "modified" lump sum applies if you want treaty benefits. See modified lump sum and tax treaties.

What changes in 2026 and beyond?

• The federal minimum rose to CHF 435,000 on 1 January 2026, and several cantons indexed their figures too (Geneva CHF 426,357; Lucerne CHF 647,100; Solothurn CHF 412,800; Uri, Glarus and Graubünden CHF 435,000).
• The imputed rental value on owner-occupied homes is due to be abolished from 1 January 2029. How that will affect the "seven times rental value" test for owners is not yet settled, so treat any firm answer with caution.
• The proposal for a 50% federal inheritance and gift tax above CHF 50 million was rejected by voters on 30 November 2025.

How we help

We look at whether the lump sum really fits your family, which cantons suit you, and how the tax and permit files fit together. We then prepare the application and the ruling request with you and stay with you through the annual returns. If you would like an indicative view of your route first, start with the eligibility check.

This guide is general information as of 30 September 2026; your own situation needs a ruling or personal advice before you rely on it.