SWISS RESIDENCE PERMIT BY LUMP-SUM TAXATION (SWITZERLAND’S GOLDEN VISA)

The Swiss Lump-Sum Tax Residency Scheme - widely known as Switzerland’s Golden Visa - offers an attractive immigration route for high-net-worth individuals seeking Swiss residency through an investment in the Swiss economy, without the need to establish a business or engage in employment. This exclusive Swiss investment visa pathway enables non-EU/EFTA nationals to relocate to Switzerland without the need to establish a business, enter employment, or disclose worldwide income and assets to the Swiss tax authorities.

The lump-sum taxation route to residency in Switzerland is particularly suited to wealthy individuals wishing to optimise their global tax position while benefiting from the political stability, security, and high quality of life that Switzerland offers. Under the lump-sum taxation regime, foreign nationals are taxed, not on their global income or wealth, but on an amount calculated based on their living expenses in Switzerland. For most cantons, the minimum tax base translates to an annual tax liability ranging from approximately CHF 250,000 to CHF 500,000 or more, depending on the canton of residence and lifestyle level.

Successful applicants for this Swiss investor visa - and their immediate family members - are issued a Swiss B Residence Permit, with the possibility of applying for a Swiss C Permit (permanent residence) after five or ten years, depending on nationality and integration efforts. Over time, this route may also lead to Swiss citizenship by investment, provided that all residency and integration requirements are met and the individual exits the lump-sum taxation regime.

The Swiss residence permit by lump-sum taxation is best suited to very wealthy retirees, international investors, and global elites seeking residency in Switzerland without business activity. However, for those who either lack the substantial assets needed to make this route financially viable or who intend to operate a company in Switzerland, the Swiss Residence Permit for Business Founders and Entrepreneurs - also known as the Swiss Entrepreneur Visa - provides a robust alternative to the Switzerland Golden Visa.

Key Benefits of Swiss Residency by Lump-Sum Taxation (Switzerland’s Golden Visa)

The Swiss Golden Visa via lump-sum taxation offers numerous advantages for high-net-worth individuals seeking residence by investment in Switzerland:

• Residency by investment in Switzerland’s economy through a tax-efficient structure based on living expenses rather than global income.

• Ideal for wealthy individuals seeking a non-commercial path to Swiss residency while continuing business activities abroad.

• 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 for the main applicant and accompanying spouse and children (C Permit) after either 10 years or 5 years for some nationalities (USA and Canada), subject to meeting integration criteria, including some knowledge of the locally spoken language.

• A potential path to Swiss citizenship by investment, subject to satisfying long-term residence and naturalisation criteria and exiting the lump sum taxation scheme.

Requirements for a Swiss Investment Visa via Lump-Sum Taxation

To qualify for a Swiss residence permit by lump-sum taxation, commonly known as the Switzerland Golden Visa, the following eligibility criteria apply:

• Nationality: The applicant and their spouse must both be non-Swiss nationals;

• New or Returning Resident: The applicant and their spouse must be taking up Swiss residence for the first time or after a 10-year absence;

• Annual Lump-Sum Tax: Applicants must possess substantial personal wealth that renders the payment of the agreed annual lump-sum tax - negotiated with the cantonal tax authorities - financially justifiable;

• High-Value Residence: Residence must be established in a high-value property within Switzerland;

• Physical Presence: The applicant and their family must intend to make Switzerland their primary home, spending a minimum of 183 days per year in the country;

• No Gainful Activity in Switzerland: Applicants and their spouses must not engage in any gainful employment or commercial activity within Switzerland, except for the active management of their own assets and investments. Business interests and professional activity conducted abroad are permitted;

• Clean Criminal Record: Applicants must demonstrate good character and have no record of serious criminal convictions.

This residence by investment in Switzerland pathway for high-net worth individuals is available in various cantons such as Vaud, Geneva, Ticino, Zug, Bern, Obwald and Neuchatel.

Swiss Lump-Sum Taxation: Key Details for Investor Visa Applicants

The key component of the Swiss Golden Visa is the lump-sum taxation.

To qualify for Swiss residence by lump-sum taxation, applicants must enter into a lump-sum taxation agreement with the cantonal tax authority.

The annual tax payment is calculated based on the applicant’s worldwide living expenses rather than global wealth or income. However, the tax base may not be lower than:

• The equivalent of seven times the annual rental expense or rental value of the applicant’s principal residence in Switzerland.

• A minimum expenses threshold of CHF 429,100 at federal level. Cantons also define minimum expenses thresholds at their own discretion.

Individuals who are taxed in Switzerland on the basis of expenditure under the lump-sum taxation regime may, in certain cases, benefit from Switzerland’s network of double taxation treaties. Eligibility to claim treaty benefits depends on the terms of the specific convention concluded between Switzerland and the other contracting state, and may be subject to additional conditions or limitations based on the taxpayer’s country of origin and residence status.

The precise amount of the lump-sum tax is determined on a case-by-case basis through direct negotiation with the relevant cantonal tax authority.  This initial tax agreement process typically takes between three to four weeks and is concluded prior to submitting a Swiss residence by investment application. Once a tax agreement is finalised, the subsequent application for a Swiss residence permit generally requires an additional four to eight weeks, subject to the processing times of the cantonal and federal immigration authorities.

The minimum net annual tax payment for non-EU nationals seeking Swiss residency via lump-sum taxation typically ranges from CHF 250,000 to CHF 500,000 or more, depending on the canton and personal circumstances.

Each application for residence by investment in Switzerland is bespoke, and negotiation is essential to securing an acceptable tax ruling.

The lump-sum tax option is fully available in all cantons and is particularly used by the Cantons of Geneva, Vaud, Valais, Ticino and Zug. The cantons of Zurich, Basel Landschaft, Basel Stadt, Schaffhausen, and Appenzell Ausserrhoden have abolished their cantonal and communal lump-sum taxation regimes. Nevertheless, since federal legislation permits the application of lump-sum taxation for federal income tax purposes, it is also possible to apply for limited lump-sum taxation in these jurisdictions.

Physical Presence Requirement for Swiss Residency by Investment

To secure Swiss residence through lump-sum taxation, applicants must establish Switzerland as both their tax domicile and primary centre of interests. For families, this typically means Switzerland becomes the location where children attend school and where the family conducts its principal activities. Additionally, applicants must physically reside in Switzerland for at least six months (183 days) per year to maintain their residency status.

As such, when applying for residency in Switzerland through investment, applicants must 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.

Restrictions on Gainful Activity in Switzerland

Under Switzerland’s Golden Visa lump-sum taxation regime, individuals are prohibited from engaging in gainful employment or conducting business activities within Switzerland, whether as employees or self-employed persons. The permissibility of serving as an unpaid board member of a Swiss-based company under this regime remains subject to legal uncertainty and is debated among practitioners. Managing one’s own assets and investments is in principle allowed. 

Family Members and the Switzerland Golden Visa

The Swiss investment residence permit is a viable pathway for families seeking to relocate to Switzerland. The Swiss B Residence Permit obtained via this route typically extends to immediate family members, allowing spouses and dependent children to accompany the main applicant and establish residence in Switzerland.

Spouses or registered partners are generally eligible for a derivative residence permit linked to the main applicant’s B Permit. Dependent children, in case of Non-EU nationals under the age of 18 - and in some cantons, under 25 if in full-time education - may also be included in the application. This makes the Swiss Golden visa particularly attractive to those seeking to relocate their family while securing a stable and advantageous residency status in a highly developed country.

While the principal applicant and the spouse are not permitted to undertake gainful activity in Switzerland, children will have access to Switzerland’s world-class education system, whether through the public system or a wide selection of private and international schools.

Pathway to Swiss Citizenship by Investment: Integration and Naturalisation

Once granted a B Residence Permit under the lump-sum taxation regime, individuals may, in principle, apply for a C Permit (permanent residence) after ten years of continuous legal residence in Switzerland - or in some cases after just five years - depending on nationality, integration efforts, and the specific terms of the cantonal lump-sum tax agreement.

Obtaining a Swiss passport by investment is not automatic; however, following the acquisition of permanent residence, applicants may pursue Swiss citizenship by investment through ordinary naturalisation, provided they no longer rely on the lump-sum taxation regime and are able to meet Switzerland’s stringent integration criteria.

Integration requirements for Switzerland citizenship by investment vary by canton but typically include proof of language proficiency (usually A2 spoken and A1 written in a national language), evidence of social and cultural integration, absence of a criminal record, and a demonstrated commitment to active participation in Swiss community life.

Exit Strategy and Flexibility

If a resident decides to leave Switzerland, the process of terminating their residence permit is relatively straightforward. The individual must inform the cantonal immigration authorities and tax office of their departure and settle any outstanding financial obligations under the lump-sum tax agreement. There are no exit taxes specific to the regime, but careful coordination with Swiss tax advisors is recommended to ensure a compliant transition.

In certain cases, it may also be possible to transition from the lump-sum tax permit to another form of Swiss residence. For example, if an individual later wishes to engage in gainful employment or set up a business in Switzerland,

Maintaining flexibility is also important for family planning, succession planning, or changes in global tax residency strategy.

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

The process of obtaining a Swiss residence permit through the lump-sum taxation scheme is structured but highly bespoke. Each application is evaluated individually by the relevant tax and immigration authorities, and success depends not only on meeting the eligibility requirements but also on strategic planning, thorough preparation, and effective negotiation.

The key stages of the application process for a Swiss residence permit under the lump-sum taxation regime are as follows:

Stage 1: Initial Consultation and Eligibility Assessment

The first step involves a detailed assessment of your personal circumstances, and residency intentions. During this stage, our Swiss immigration lawyers and tax specialists will determine whether you qualify for Swiss residence by investment through lump-sum taxation. Particular attention will be paid to your financial standing, nationality, absence of recent Swiss residence, and ability to satisfy the physical presence requirement. Based on your tax optimisation objectives and lifestyle preferences, we will assist you in selecting the most appropriate canton - bearing in mind that not all cantons offer the full lump-sum taxation regime and that tax rates and administrative practices vary significantly between cantons.

Stage 2: Negotiation of Lump-Sum Tax Ruling

Once a suitable canton has been selected, we will initiate direct discussions with the cantonal tax authorities to negotiate a bespoke lump-sum tax agreement. This tax ruling will establish the annual tax liability you will pay as the basis for your Swiss residence. The calculation will typically be based on your annual living expenses and, in many cantons, a multiple of your Swiss housing costs. The tax ruling process generally takes three to four weeks and is the most critical part of securing approval for the Swiss residence permit. 

Stage 3: Preparation and Submission of Residence Permit Application

With a tax ruling in place, the next stage is to prepare and submit the application for a B Residence Permit under the investment route. This involves compiling a comprehensive portfolio of documents, including the tax ruling, evidence of accommodation in Switzerland and medical insurance. We can also assist with drafting all the necessary declarations and covering statements to confirm your residency intentions. The full application will then be lodged with the cantonal immigration authority. Processing times for a lump-sum taxation residence application typically ranges from four to eight weeks, depending on the canton and the complexity of the case.

Stage 4: Decision and Issuance of Swiss B Permit

Following a successful review of the residence application, the cantonal authority will issue a formal approval and grant a Swiss B Residence Permit. This permit will confer the right to reside in Switzerland on the basis of the lump-sum taxation agreement and must be renewed annually or bi-annually. Once issued, the applicant is expected to relocate to Switzerland, establish their primary residence in the chosen canton, and begin fulfilling the ongoing conditions of residence, including the annual tax payment and minimum physical presence requirement.

At Richmond Chambers Switzerland, our team of senior Swiss immigration advisors and Swiss tax experts provides a full end-to-end service for high-net-worth individuals seeking residence in Switzerland by investment. From initial consultation through to tax ruling negotiation, document preparation, and permit issuance, we manage the entire process with discretion, efficiency, and precision. Our bespoke legal and tax guidance ensures that your application for a Swiss investment visa is handled with the highest level of professionalism and attention to detail.

Common Mistakes in Swiss Residency by Investment Applications

One of the most frequent mistakes in lump-sum taxation applications is underestimating the true financial commitment required. The lump-sum tax payment is not a nominal fee - it typically ranges from a minimum of CHF 250,000 to CHF 500,000 or more per year, depending on the canton and personal circumstances. Applicants who fail to budget appropriately or enter negotiations without clear financial disclosures often face delays or unsuccessful outcomes.

Another significant issue arises when individuals misunderstand the residency requirement. Maintaining residence in Switzerland requires a genuine commitment to living in the country for at least 183 days per year. Attempting to treat the Swiss residence permit as a mere tax planning tool while living elsewhere is likely to result in scrutiny from authorities and potential revocation of the residence permit.

Applicants must also understand the prohibition on gainful employment. Engaging in work or operating a business in Switzerland is not permitted under this regime. Even professional activities with Swiss clients that are not remunerated may constitute a breach of the permit terms.

Additionally, the practice of the tax authorities varies from canton to canton. It is important to fully investigate the exact conditions on which the lump-sum scheme is offered in the selected canton. Not all cantons permit full lump-sum taxation, and the differences in tax calculation methods and approval policies between cantons are material. Proper canton selection is therefore critical.

Finally, inadequate preparation of financial and supporting documentation remains a recurring obstacle. Swiss authorities and tax offices expect complete, accurate, and well-organised disclosures. Applicants who cannot produce clear evidence of financial standing, tax compliance, or residency intention will struggle to secure approval.

Avoiding these mistakes is essential for high-net-worth individuals aiming to secure Swiss residency by investment through the lump-sum taxation scheme. Working with experienced legal and tax professionals from the outset can significantly increase the likelihood of a smooth, successful application.

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

For the right profile of investor, the Swiss Golden 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.

• Simplicity & Predictability: The lump-sum taxation scheme allows for predictable, pre-agreed tax payments, making it simpler to plan one’s finances without worrying about fluctuating tax rates.

• 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 Switzerland's golden visa via lump-sum taxation an appealing residence by investment option for high-net-worth individuals seeking residency in Switzerland.

Summary of Key Challenges of the Swiss Lump-Sum Taxation Scheme

While Swiss residence by investment through lump-sum tax offers many advantages, there are also several important considerations that potential applicants should evaluate before proceeding:

• High Minimum Tax Payments: The annual lump-sum tax amount for non-EU nationals range from a minimum of CHF 250,000 to CHF 500,000 or more annually. The tax amount for EU nationals may be (slightly) lower. 

• 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, the lump-sum taxation scheme remains one of the most viable and prestigious golden visa pathways in the long term.

How Richmond Chambers Switzerland Can Assist

Navigating Switzerland's residence by investment (lump-sum taxation) scheme can be complex, requiring careful planning and compliance with Swiss tax and immigration regulations. At Richmond Chambers Switzerland, we specialise in assisting high-net-worth individuals to navigate the complexities of Switzerland's immigration landscape, supported by highly qualified tax advisors.

Our professional service for individuals 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 situation and lifestyle preferences.

• Tailored Tax Ruling Negotiation: Our Swiss tax specialist 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 immigration team will guide you through the entire residence permit application process, including document preparation, application submission, and liaising with Swiss authorities.

• 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, in line with your requirements and expectations.

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 Investment Visa Lawyers in Switzerland

To speak with a specialist regarding your Swiss investment visa or to begin your application for Switzerland residence by investment, contact Richmond Chambers Switzerland on +41 21 588 07 70 or complete our enquiry form below.