SWISS RESIDENCE PERMIT BY LUMP-SUM TAXATION

The Swiss Lump-Sum Tax Residency Scheme offers an attractive Switzerland residence by investment pathway for non-EU/EFTA nationals. Through this route, wealthy individuals - such as retirees, investors, and international businesspeople - can obtain a Swiss residence permit by investment without the need to set up a business or engage in employment within Switzerland.

This form of Swiss investment visa is ideal for those seeking a simplified route to residency by making a substantial passive financial contribution to the Swiss economy via pre-agreed annual tax payments.

Successful applicants are granted a Swiss B Residence Permit, with the potential to apply for a C Permit after five or ten years, depending on nationality and level of integration. In the long term, this pathway can offer a route towards Swiss citizenship through investment, for those meeting the relevant residency and integration requirements.

Individuals considering Swiss residence via lump-sum taxation may also wish to consider the Swiss residence permit by business investment as an alternative Swiss investment residence permit option.

Key Benefits of the Swiss Lump-Sum Taxation Route

The Swiss residence permit by investment via lump-sum taxation offers several strategic advantages:

• Residency in Switzerland via a tax-efficient structure based on living expenses rather than global income.

• No business incorporation required - ideal for individuals seeking a non-commercial path to Switzerland residency by investment.

• Predictable and pre-agreed annual tax liability.

• Freedom to manage foreign investments and enjoy passive income.

• Access to Switzerland’s exceptional quality of life, healthcare, education, and infrastructure.

• Eligibility for permanent residency (C Permit) after 10 years or 5 years for some nationalities (USA, Canada, UK).

• A potential path to Switzerland citizenship by investment, subject to satisfying long-term residence and naturalisation criteria.

  
  

Requirements for a Swiss Investment Visa by Lump-Sum Taxation

To qualify for a Swiss investment visa through the lump-sum taxation scheme, applicants must meet the following criteria:

• Nationality: Be a non-Swiss, non-EU/EFTA national (EU/EFTA nationals have rights of free movement under EU Treaty Law).

• New or Returning Resident: Be taking up Swiss residence for the first time or after a 10-year absence.

• Annual Lump-Sum Tax:  Have sufficient funds available to pay an annual lump-sum tax payment of an amount to be agreed with the cantonal tax authorities.

• High-Value Residence: Be establishing residence in a high-value property in Switzerland.

• Physical Presence:  Intend to establish a main residence in Switzerland and spend at least 6 months (183 days) per year in Switzerland.

• No Gainful Activity:  Not intend to engage in Swiss employment or business (but may manage foreign investments).

• Financial Stability: Have sufficient financial resources to sustain residency.

• Clean Criminal Record: Have no serious criminal convictions.

• Optional Swiss Ties: Owning property, frequent visits, or family connections may strengthen an application.

These requirements support Switzerland’s commitment to welcoming financially independent individuals through its residence by investment programme.

Lump-Sum Taxation Details

The key component of this Switzerland residence by investment route is the lump-sum tax payment.

To qualify for Swiss residence by lump-sum taxation you will need to make a substantial financial contribution to Switzerland’s economy via a lump-sum taxation payment. 

Lump-sum taxation in Switzerland is calculated based on living expenses, rather than global wealth or income. The tax base (the amount on which tax is payable) is calculated with reference to annual expenditure on living expenses (including school fees) plus, typically, seven times the annual rental value of the applicant’s Swiss property (if owned) or seven times the annual rent (if rented), or a fixed taxable base of at least CHF 429,100 (in 2024) - whichever is higher.

Once a tax base has been calculated, the exact amount on which lump-sum tax will be paid must be negotiated directly with the relevant cantonal tax authority, and each case is unique. The process usually takes around 3 to 4 weeks.

The minimum net annual tax payment for those seeking Swiss residency via lump-sum taxation typically ranges from CHF 150,000 to CHF 350,000 or more, depending on the cantonal tax regulations and personal circumstances.  In wealthier cantons such as Vaud and Geneva, amounts at the higher end are more common.

Each application for a Swiss residence permit by investment is bespoke, and negotiation is essential to securing an acceptable tax ruling.

This tax option is available in key cantons such as Vaud, Valais, Geneva, Ticino, and Zug. However, it is not offered in Zurich, Basel, and certain other regions.

Physical Presence Requirement for a Swiss Investment Visa

To qualify for Swiss residence via lump-sum taxation, applicants must establish their main residence in the country and obtain a B residence permit, which is renewable annually. Switzerland must be the primary place of residence for tax purposes.

Most cantons require lump-sum taxpayers to spend at least six months (183 days) per year in Switzerland to maintain their residency status.

Foreign investors applying for a Swiss Investment Visa must also demonstrate an intention to live in Switzerland on an ongoing basis, rather than using the country solely as a tax base while residing elsewhere. This intention is typically assessed through various factors, including property rental or ownership, personal ties, and the amount of time spent in Switzerland.

This requirement ensures that applicants seeking Swiss residence by investment are genuinely contributing to and integrating into Swiss life.

Restrictions on Gainful Activity under the Swiss Lump-Sum Tax Scheme

Under the Swiss Lump-Sum Tax Residency regime, investors are not permitted to engage in gainful employment or business operations within Switzerland, whether as an employee or a self-employed individual.

However, passive income from foreign investments - such as dividends, interest, and rental income - is not considered gainful activity and is therefore allowed under the regime.

Cantonal policies vary in relation to owning and managing businesses outside of Switzerland. 

There are certain exceptions for international business owners. In some cases, lump-sum taxpayers may own a Swiss company, provided it only operates internationally - meaning it does not generate revenue from Swiss clients or engage in any economic activities within Switzerland.

These restrictions ensure compliance with the Swiss residence by investment programme’s core requirement of non-engagement in Swiss employment.

Strengthening Your Swiss Investor Visa Application: Swiss Ties

Although optional, demonstrating a genuine connection to Switzerland may strengthen an application for a Swiss residence permit by investment.  

Relevant considerations may include owning or renting property in Switzerland, having close family members (such as a spouse or children) residing in Switzerland, holding passive investments in Swiss assets (such as real estate or Swiss stocks), and maintaining regular travel to Switzerland or having previous long-term stays (for example, under a tourist visa or other residence permits). 

These factors can reinforce the credibility of an applicant’s residency intentions and long-term integration, showing a commitment to residing in Switzerland, rather than using the country solely as a tax haven.

Application Process for Swiss Residence by Investment (Lump-Sum Taxation)

Applying for a Swiss investment visa under the lump-sum taxation scheme typically involves the following stages:

1. Initial Consultation – Evaluate eligibility and select a suitable canton.

2. Tax Ruling Negotiation – Discuss lump-sum tax requirements with the canton and negotiate a tax agreement (3–4 weeks).

3. Residency Application Submission – File documentation and financial proof (4–6 weeks).

4. Approval & Permit Issuance – Receive Swiss B Permit for residence.

Our Swiss immigration team, comprising senior Swiss immigration advisors and tax specialists, can guide you through each step of the Switzerland residence by investment process.

Swiss Investment Permit Outcome

• B Residence Permit: Issued initially for one year, renewable annually.

• C Residence Permit: Eligibility after 5 or 10 years, depending on nationality and integration.

• Long-term residents may pursue Swiss citizenship by investment through naturalisation, provided they meet residency and cultural integration requirements.

  
  

Key Advantages of the Swiss Lump-Sum Taxation Regime for High-Net-Worth Individuals

For the right profile of investor, the Swiss investment visa offers a compelling route to securing long-term residence in one of the world’s most desirable countries.

• Tax Efficiency: The lump-sum tax is based on living expenses rather than worldwide income, offering significant tax advantages for individuals with substantial wealth or passive income overseas but modest living expenses in Switzerland.

• Simplicity & Predictability: The lump-sum taxation scheme allows for predictable, pre-agreed tax payments, making it simpler for investors to plan their finances without worrying about fluctuating tax rates based on income.

• High Standard of Living: Switzerland offers a high standard of living, with access to top-tier healthcare, infrastructure, security, and education, making it an attractive option for high-net-worth individuals looking for a luxurious lifestyle.

These benefits make the lump-sum taxation route one of the most attractive Switzerland investment residency options for high-net-worth individuals.

Key Challenges of the Swiss Lump-Sum Taxation Scheme

While the Swiss residence permit by investment offers many advantages, there are also several important considerations that potential applicants should evaluate before proceeding:

• High Minimum Tax Payments: The lump-sum tax can range from CHF 150,000 to CHF 350,000 or more annually, which may be a financial burden for individuals with lower wealth or fewer assets.

• No Gainful Employment: Applicants for residency in Switzerland via the lump-sum tax programme cannot engage in employment or business activity within Switzerland, limiting opportunities for active involvement in the Swiss economy and professional engagement.

• Strict Physical Presence Requirement: To maintain residency, individuals must typically spend at least 6 months (183 days) per year in Switzerland, which might not be feasible for individuals who prefer to split their time between multiple countries.

Despite these challenges, for financially qualified individuals with a genuine intention to reside in Switzerland, the lump-sum taxation scheme remains one of the most viable and prestigious Switzerland citizenship by investment pathways in the long term.

How Richmond Chambers Switzerland Can Assist

Navigating the Swiss Residence by Investment (Lump-Sum Taxation) scheme can be complex, requiring careful planning and compliance with Swiss immigration and tax regulations. At Richmond Chambers Switzerland, we specialise in assisting high-net-worth individuals to navigate the complexities of the Switzerland residence permit by investment route.

Our professional service for investors applying for a Swiss Residence Permit by Lump-Sum Taxation includes:

• Eligibility Assessment: We will evaluate whether you meet the criteria for Swiss residency under the lump-sum taxation scheme and advise you on suitable cantons based on your financial and lifestyle preferences.

  
  

• Tailored Tax Ruling Negotiation: We will assist in negotiating a lump-sum tax agreement with the relevant cantonal tax authorities, ensuring clarity on tax obligations before submitting your residence permit application.

  
  

• Comprehensive Application Support: Our team will guide you through the entire residence permit application process, including document preparation, financial proof submission, and liaising with Swiss authorities.

  
  

• Coordination with Swiss Tax and Legal Experts: We will work closely with leading Swiss tax advisors, private banks, and legal professionals to ensure that your move is structured in a tax-efficient manner while ensuring full compliance.

  
  

• Ongoing Compliance and Renewal Assistance: Once you obtain your Swiss B Permit, we will provide ongoing support to help you maintain residency, renew your permit, and transition to a C Permit or Swiss citizenship by investment, if eligible.

  
  

With our in-depth knowledge of the Swiss immigration system, Richmond Chambers Switzerland offers a seamless, end-to-end service for individuals seeking to establish residency in Switzerland through the lump-sum taxation scheme - from initial consultation, to C Permit transition and Swiss citizenship by investment. .

Contact Our Swiss Immigration Lawyers in Switzerland

For tailored advice on the Swiss residence by investment route and expert assistance with your Swiss investment visa application, contact our immigration lawyers in Switzerland on +41 21 588 07 70 or complete our enquiry form below.