Tax ruling service for new Swiss residents

Moving your life to another country is hard to reverse. A tax ruling lets you find out, in writing, how the cantonal tax authority will treat your situation before you sell a house, sign a lease or take the children out of school. For families moving to Switzerland on a lump-sum basis, or with an unusual mix of income and assets, it is usually the single most useful document in the whole file.

What a ruling is, and what it is not

A ruling (Steuerruling, Vorbescheid, ruling fiscal) is a written, advance assessment by the cantonal tax authority of a concrete set of facts that is actually about to happen. It is not an opinion on a hypothetical plan. Zurich's official tax manual says plainly that hypothetical planning questions are not answered; the exact ruling practice is worth confirming with the canton concerned, since it is not published the same way everywhere.

Under the constitutional principle of good faith, a ruling binds the authority if:

• it was given without reservation, to you, on concrete facts
• the authority that gave it was competent
• you could not see that it was wrong
• you relied on it in ways you cannot undo without harm
• the law has not changed since

This is why the quality of the request matters so much. A ruling protects you only for the facts it describes. If the facts you present are incomplete, or your situation later differs from them, its protection weakens.

What this service covers

• defining the question: what exactly needs to be confirmed, and by which authority
• assembling the facts: family, nationality, income sources, assets, planned home and lifestyle
• drafting the ruling request in the canton's working language
• supporting documents, such as the lifestyle budget and lease or property valuation
• discussions with the tax administration until a written answer is issued
• checking that the answer matches what your residence permit application says

Who it is for

• families applying for lump-sum taxation, where the amount is agreed with the canton before or on arrival
• non-EU nationals using the fiscal-interest permit route, where the migration office needs to see your tax position
• people with assets or income that raise a specific question, for example foreign pensions, holdings in a family company or income from a treaty country that requires the modified lump sum
• anyone who wants certainty before committing to a canton

How we work

1. Scoping call. We identify the questions that genuinely need a ruling and those that do not.
2. Canton check. Procedures differ. In Geneva, you propose a lump-sum amount together with a lifestyle form ("train de vie"), your lease or property valuation, and a letter confirming no gainful activity in Switzerland. In Vaud, the signed lump-sum agreement is itself one of the required documents for the non-EU permit. In Zurich, which has no lump-sum regime, the fiscal-interest permit needs a tax-authority confirmation of an expected annual tax of about CHF 1 million.
3. Drafting. We write a clear, complete description of the facts and the treatment you are asking the authority to confirm.
4. Dialogue. The tax administration may ask questions or propose a different figure. We handle the exchange and explain each step to you.
5. Signed outcome. You receive the written answer or agreement, with a short note on what it covers, what it does not, and what would make it lapse.
6. Hand-over. The ruling is passed to the team handling your permit and, after arrival, your annual returns.

We work with Ark Fiduciaire SA in Geneva on the tax side, so the people who negotiate the ruling are also familiar with the returns that follow it.

What you get

• a ruling request built on precise, documented facts
• one point of contact with the cantonal tax administration
• a written outcome you can rely on, within the limits of good faith
• a consistent story across your tax and migration files
• a list of changes you must report later, since lump-sum taxpayers must tell the authority about changes without being asked

We cannot promise what the canton will accept. The authority decides, and cantonal practice varies.

Typical questions we solve

• "Will the canton accept our proposed lump-sum base, given the house we plan to rent?"
• "Is keeping a non-executive board seat abroad compatible with no gainful activity in Switzerland?"
• "How will my Swiss pension and my Swiss shares enter the control calculation?"
• "We hold income from Germany. How will the modified lump sum apply to us?"
• "Can we get the ruling before the permit, or do they have to run together?"

Related reading

• Securing a tax ruling before moving
• How the lump-sum tax is calculated
• Living in Geneva
• Living in Vaud
• Our lump-sum taxation service

Talk to us about your ruling

Every ruling starts with a precise description of your situation. If you would like to discuss yours in confidence, get in touch.