Swiss Lump-Sum Taxation in 2026: CHF 435,000 Federal Base, Cantonal Minimums and How It Leads to a Residence Permit

Lump-sum taxation, in German Besteuerung nach dem Aufwand, is the Swiss regime that clients with large foreign income ask me about most. It has existed for decades and is set out in Article 14 of the Federal Direct Tax Act and in circular no. 44 of the Federal Tax Administration. Below is how it works in 2026 and what people usually get wrong.

Who qualifies

According to circular no. 44, you can be taxed on expenditure if all of the following apply:

• you do not have Swiss citizenship;
• you take up residence in Switzerland for the first time, or come back after at least ten years abroad;
• you carry on no gainful activity in Switzerland.

Managing your own assets is allowed, and work abroad is not an obstacle for the tax regime. For a married couple living together, both spouses must meet the conditions. In practice this means the spouse cannot take a Swiss job either.

How the tax base is set

The base is your worldwide annual living expenditure, and it must be at least the highest of these amounts:

Test	2026
Federal minimum (Art. 14 para. 3 a DBG)	CHF 435,000
Own home or rented home	7 times the annual rent or rental value
Living in a hotel or with full board	3 times the annual board and lodging price
Control calculation	tax on certain Swiss-source income

The federal minimum is indexed. The Federal Tax Administration gives CHF 434,700 for 2025, CHF 435,000 for 2026 and CHF 437,000 for 2027. The control calculation adds up gross income from Swiss sources: Swiss property, movable assets and capital invested in Switzerland, copyrights and patents used in Switzerland and Swiss pensions. If the ordinary tax on that income is higher, it applies.

Cantonal rules and typical amounts

Each canton sets its own minimum for cantonal and communal tax and usually adds wealth tax. The canton of Bern, for example, uses a minimum of CHF 400,000. Zurich abolished the regime from 2010, followed by Schaffhausen, Appenzell Ausserrhoden, Basel-Landschaft and Basel-Stadt, according to the Federal Finance Department. At the end of 2018, 4,557 people were taxed this way and paid CHF 821 million in total.

BRIDGES gives practical guides for the total tax: from about CHF 250,000 a year in central cantons such as Zug, Schwyz and Lucerne and from CHF 300,000 in Geneva, Vaud, Valais and Ticino. These are estimates from practice, not official figures. The exact amount is agreed with the cantonal tax office before the move.

The residence permit is a separate decision

This is the point I explain to every family. A tax ruling does not give the right to live in Switzerland. A non-EU national who will not work needs a permit from the cantonal migration office. Under 55, the usual ground is “important cantonal fiscal interests” under Article 30 para. 1 b of the Foreign Nationals Act together with Article 32 of the Ordinance. The canton of Zurich, for instance, describes in its directive that it expects close ties to the canton, no work in Switzerland or abroad apart from managing your own assets, the whole family moving and an annual tax of around CHF 1 million confirmed by the tax office. Zurich does not offer lump-sum taxation, so there this applies to ordinary taxation. Other cantons have their own practice. From age 55, the retiree route is another option.

My honest view

Lump-sum taxation is expensive, but it is predictable. You know the tax before you move, and it does not grow with income earned abroad. It only makes sense if you will really live in Switzerland and nobody in the couple needs a Swiss job. I always ask clients to compare two or three cantons, the home they want and the wealth tax before they choose. If you want to work, look at the business route instead. The overview is in the complete guide.