Planning roadmap for expats in Switzerland (2026) Part One

PART ONE

This article is the first of the three-part series discussing some key planning points for expats in Switzerland. Asset planning is the key focus of this part one. Part two deals with succession planning, and incapacity planning and children matters are addressed in the final part.

Introduction

When we first wrote on this topic in 2020, the world was a somewhat different place. Over the last five years we have seen shifting political leaderships, an influx of tax and mobility regime changes, budget cuts and an expansion of geographical risk across the globe. Add in a global health pandemic and it is not surprising that the way people view their lifestyle choices is changing. Reviews of residence have accelerated and given the world’s uncertainties, flexibility for mobility has never been more crucial. 

Family considerations, as well as asset and succession planning are an important part of life no matter where you reside, but they become even more pertinent when you are connected with multiple countries. It is next to impossible to move around the world and not leave a trace; very often people find themselves nationals of one country, resident in another and owning property and other assets in a third and fourth country without even trying, simply as a result of living a ‘normal’, mobile life. Legal and tax rules in one country usually differ in another, and so time should be dedicated to working through the maze and coming up with a solution that works for each family.

Asset planning – what do I have, and where is it?

Understanding your asset base is a fundamental starting point. Work out what you own, both outright and jointly with others. You may also as a beneficiary of a trust (sometimes as part of a family inheritance), or indeed you may have settled a trust yourself, or be a shareholder of a corporate structure or other asset holding vehicle.

Planning can only be put in place effectively if you know what you have.

Often, the driving force behind a planning exercise is tax efficiency, and being an expat usually means that your planning needs to work on a global scale taking both an immediate and longer-term view. It is not always true that once you leave your hometown, you will no longer be subject to its tax or succession rules or reporting obligations. For example, if you are a Swiss resident and you receive rental income from a property investment in the UK, both Switzerland and the UK may seek to charge this to tax. Similarly if you were looking to buy or sell property, or gift assets during your lifetime as part of a wider succession planning picture: the tax triggers in all relevant countries need to be thought through. Tax treaties exist to prevent double taxation in some circumstances, but careful planning needs to be put in place to understand and make use of these.

In addition, long gone are the days of full banking secrecy in Switzerland. The implementation of worldwide transparency regimes mean that your planning not only has to be smart, but it has to be consistent as information will be shared between Switzerland and other countries in which you hold assets or are liable to pay taxes.

For those moving into Switzerland – there is an attractive tax regime on offer for expats which would be worth investigation for some people. Existing structures and planning vehicles may also need to be tweaked in order to fit comfortably with the Swiss system. For those leaving Switzerland, you may be retaining property or other assets in your name for investment or private-use purposes. In these circumstances, Swiss taxes and other obligations may not always be a distant memory after departure.

It is not only your personal position which needs thought – business planning is also an essential factor. Unintentional migration of a business’s residence to or from Switzerland can cause an unnecessary sting, and so business connections (including both shareholdings and directorships) and your ability to continue working in certain capacities whilst in or leaving Switzerland need careful consideration. It goes without saying that profit extraction from both Swiss and foreign businesses whilst in Switzerland also should not be given the green light without sufficient forethought, particularly if you know you’ll soon be on the move elsewhere.

Thoughts on succession planning? Read part two of our series for more.

For more information, please contact Sophie Hart on sophie.hart@crsblaw.com / +41 (0)22 591 17 54