Swiss lump-sum taxation: the forfait, canton by canton

What is actually true

• There are three conditions, and all three are absolute. You must not be a Swiss citizen. You must be taking up Swiss tax residence for the first time, or after at least ten years of absence. And you must not carry on any gainful activity in Switzerland. Managing your own private assets and earning income abroad are both permitted. For married couples, both spouses must independently satisfy all three conditions. A Swiss-citizen spouse defeats the regime for the whole household.
• The right lapses the moment you acquire Swiss citizenship or take up employment in Switzerland. The forfait and naturalisation are mutually exclusive. That matters for anyone treating Switzerland as a path to a passport rather than simply a place to live.
• The tax base is your deemed annual living expenditure, and it has floors. It cannot be less than seven times the annual rent or rental value of your primary residence, or three times the pension price for those living in a hotel. It cannot be less than your actual worldwide living expenses. And it cannot be less than the statutory minimum. The federal minimum taxable base is CHF 434,700. That base is then taxed at ordinary federal, cantonal and communal rates. The forfait changes what gets taxed. It does not change the rate applied.
• Cantons set their own minimums, and they are higher than the federal floor. This is where the real negotiation happens. Cantonal minimums generally run from roughly CHF 400,000 to CHF 600,000 and above. EU/EFTA nationals often face a lower entry point than third-country nationals. Most cantons also compute a federal wealth-tax equivalent, based on a multiple of the expenditure base.
• Five cantons have abolished the regime outright: Zurich (by popular vote in 2009, effective January 2010), Schaffhausen, Appenzell Ausserrhoden, Basel-Landschaft and Basel-Stadt. Four more, Thurgau, St Gallen, Lucerne and Bern, kept it but tightened the conditions. The regime survives in the remaining cantons. Vaud, Valais, Ticino, Geneva, Zug, Schwyz, Grisons, Obwalden and Nidwalden are the ones actually used at scale.
• It is a small, visible population. Fewer than 0.1% of Swiss taxpayers are taxed on an expenditure basis. At the end of 2018 the figure was 4,557 people, generating CHF 821 million in tax. This is not a mass-market regime. It has survived two national abolition attempts precisely because that revenue figure is easy to defend.

Jurisdiction by jurisdiction

Switzerland — federal floor low

The federal minimum taxable base is CHF 434,700, or seven times the rent or rental value of the main residence, or actual worldwide living expenses, whichever is highest. It is taxed at ordinary rates. The federal floor is the starting point, not the answer. The cantonal floor is almost always higher.

Switzerland — Vaud, Valais, Ticino, Geneva medium

These are the cantons where the forfait is genuinely used at scale for UHNW arrivals. Cantonal minimum expenditure bases run broadly in the CHF 400,000–600,000+ range, negotiated in a binding advance ruling with the cantonal administration before you move. Actual all-in annual tax commonly lands in the low-to-mid six figures CHF, but it is entirely canton- and commune-specific.

Switzerland — Zurich, Basel-Stadt, Basel-Landschaft, Schaffhausen, Appenzell Ausserrhoden high

Abolished. Zurich voted it out by referendum in 2009, effective January 2010, and the other four cantons followed. Federal lump-sum taxation technically remains available to a resident of these cantons, but it is pointless. Full ordinary cantonal and communal taxation applies on worldwide income and wealth instead.

Switzerland — Thurgau, St Gallen, Lucerne, Bern medium

This canton kept the regime but tightened the conditions and raised the floors relative to the classic cantons. It is available, but generally not competitive against Vaud, Valais or Ticino for a family that has a real choice.