Relocation to Switzerland

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05/2026

Relocating to Switzerland: Key Legal and Tax Pitfalls Wealthy Families Should Avoid

Switzerland continues to attract internationally mobile families thanks to its political stability, strong rule of law, predictable tax environment and quality of life. Yet, in practice, relocation is rarely straightforward. The most common issues arise not from the move itself, but from legal and tax matters that are addressed too late.

Against the background of current laws, the following areas deserve particular attention (the list is not to be understood as exhaustive).

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1. Pre-Immigration Planning in relation to Trusts and Structures

Moving tax residency to a different country always warrants particular attention; timely planning may help avoid tax risks (e.g. Swiss re-qualification risks) and even allow for optimization. For instance, trusts are recognized in Switzerland, but their tax treatment differs fundamentally depending on structure and control. The same is true for other structures.

Key questions include:

  • How is the existing structure treated? Transparent or opaque? Where is the effective place of management?
  • Should the structure be adjusted prior to relocation? Does it make sense to set up a different / new structure before relocation?
  • Is a tax ruling advisable before establishing Swiss residence?  

Addressing these issues post‑relocation is often significantly more complex and potentially costly.

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2. Taxation in general: Lump‑Sum vs Ordinary Taxation / Estate and Gift Tax

For non‑Swiss nationals relocating without gainful activity, lump‑sum taxation (forfait fiscal) may be available, but eligibility and minimum tax bases vary significantly by canton. Some cantons no longer offer lump‑sum taxation at all; others impose high minimum thresholds. With regards to the requirement of gainful activity in Switzerland, even seemingly limited or passive activities should be assessed.  

In parallel, the advantages of benefitting from the ordinary tax system should not be underestimated. Switzerland levies wealth tax at cantonal level, and income tax rates vary substantially between cantons and municipalities. Early modelling and cantonal comparison are essential.

Also, while there are no estate and gift taxes on federal level, cantons may levy such taxes. In most cantons, transfers to direct descendants and spouses are tax-free. Nevertheless, and depending on the specific situation, it makes sense to also take this point into account.

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3. Immigration: Nationality / Real Estate / Physical Move

Swiss immigration law follows a dual admission system. EU/EFTA nationals benefit from freedom of movement, while third‑country nationals are subject to a restrictive permit system with quotas and discretionary approval.

Depending on the nationality the conditions for settlement in Switzerland vary, so do the cantonal practices.

In addition, it is noteworthy that depending on your nationality, different requirements apply with regards to acquiring a home in Switzerland.

In very practical terms, it is also important to properly plan your physical move to avoid negative surprises at the border; questions of timing as well as categories of goods (e.g. art) you own are important in this regard.

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4. Family Law, Succession and Capacity Planning

Relocating to Switzerland can automatically change the applicable matrimonial and inheritance law, often without the family realizing it.  

Absent planning:

  • Swiss matrimonial property law may apply
  • Swiss intestacy and forced heirship rules may govern succession
  • Swiss law applies to incapacity, guardianship and child protection

Pre‑arrival review of marriage contracts, wills, choice‑of‑law clauses, powers of attorney and guardianship arrangements is therefore critical for multinational families.

5. Beneficial Ownership Transparency

Relocating to Switzerland also increasingly raises questions around beneficial ownership transparency. Switzerland is moving towards a more centralized approach to beneficial owner information, in line with international standards on anti‑money laundering and transparency.

This does not mean public disclosure. However, it does mean that ownership and control structures must be reported, including trustees domiciled or operating from Switzerland. Structures may draw closer scrutiny once beneficial owners are reported.

Conclusion: Relocation Is a Governance Project

A move to Switzerland is not merely an administrative step. For wealthy families, it is a comprehensive governance project covering immigration, taxation, asset structuring and family law across borders.

Early planning, canton‑specific analysis and coordination between tax, legal and family office advisors are key to avoiding unpleasant surprises — and to ensuring that Switzerland delivers what families seek most: stability, predictability and continuity across generations.

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Marcuard Family Office acts as project manager and guides families with external specialists through this often challenging transition with a strategic, long-term approach that fosters continuity, stability, and lasting prosperity.

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Denise Schmid

Head Tax, Legal & Compliance, Managing Partner
Über MFO
Marcuard Family Office wurde 1998 in Zürich gegründet und ist ein unabhängiges, partnergeführtes Multi-Family Office.
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Als Family Office kümmern wir uns umfassend um alle relevanten Vermögensthemen. Damit Ihnen Zeit bleibt für andere Dinge.
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Ganz gleich, ob Sie Ihr Unternehmen verkaufen, die aktuelle Situation restrukturieren, oder schwierige familiäre Verhältnisse meistern – die damit verbundenen Herausforderungen können überwältigend sein. Als erfahrene Berater begleiten wir Sie professionell durch Phasen des Übergangs und auch durch ruhigere Zeiten.
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