---
name: ch-lump-sum
description: "Switzerland lump-sum taxation (Pauschalbesteuerung / taxation selon la dépense): for non-working foreign nationals resident in Switzerland. Tax based on living expenses rather than actual income. Trigger on: \"Switzerland lump sum tax\", \"Pauschalbesteuerung\", \"Switzerland forfait fiscal\", \"move to Switzerland taxes\", \"Switzerland non-working resident tax\", \"Switzerland 5x rent tax\", \"Switzerland special tax regime\". ALWAYS load before advising on Switzerland tax for non-working foreign nationals."
license: "AGPL-3.0-or-later (code) / OpenAccountants Guide License v1.0 (content)"
metadata:
  source: openaccountants
  openaccountants_url: "https://www.openaccountants.com/skills/ch-lump-sum"
  jurisdiction: "CH"
  tax_year: "2025"
  last_updated: "2026-07-13"
  review_status: "pending_review"
---

# CH Lump Sum

## Quick reference

**Quick reference**  _(DBG Art. 14; StHG Art. 6)_

| Item | Value |
| --- | --- |
| Official name | Pauschalbesteuerung (DE) / Imposition d'après la dépense (FR) |
| Available to | Foreign nationals who are NOT gainfully employed in Switzerland |
| Tax base | Annual living expenses (not actual income) |
| Minimum tax base | 7× annual rent or rental value of Swiss residence |
| Cantons | Available in most cantons (a few abolished it: ZH, SH, AR, AI, BL, BS) |
| Legislation | DBG Art. 14; StHG Art. 6 |

## Who can use lump-sum taxation

- **Condition 1: Swiss resident** — Swiss resident (must have permit — B or C permit acceptable)
- **Condition 2: Not a Swiss citizen** — Not a Swiss citizen
- **Condition 3: Not gainfully employed in Switzerland** — Not gainfully employed in Switzerland — no salary, no business income from Switzerland. Investment income and foreign business income are fine.
- **Condition 4: First time establishing Swiss residence** — First time establishing Swiss residence (or returning after 10+ years absence)
- **Spouses/partners filing together** — Spouses/partners must both meet the conditions if filing together.

## How the tax base is calculated

- **Tax base calculation** — Tax base = MAX of: (a) 7 × annual rent (or rental value if owner-occupied) (b) Actual living expenses (worldwide) if higher (c) Cantonal minimum amounts (vary by canton — e.g. CHF 400,000 in some)
- **Cantonal minimum tax bases (examples)** — Some cantons have set explicit minimum tax bases (e.g. Valais: CHF 250,000; Vaud: CHF 250,000; Geneva: CHF 400,000; Ticino: CHF 500,000).
- **Federal minimum tax base** — CHF 451,200 CHF (2025, indexed annually)

## Tax rates applied

- **Applicable tax rate on lump-sum base** — The agreed tax base is taxed at ordinary Swiss income tax rates (federal + cantonal + communal). No special reduced rate — the benefit is the smaller base.
- **Effective all-in rates on typical lump-sum bases** — 15%–35% % (depending on canton and base amount; federal + cantonal + communal combined)

## Treaty benefits

- **Treaty benefits limitation** — Switzerland's extensive DTA network is NOT fully available to lump-sum taxpayers. Treaty reduced withholding rates require that the taxpayer is subject to Swiss tax on the specific income in question. For most DTAs, treaty benefits are only available on income up to the tax base amount.

Practical impact: lump-sum taxpayers may not reclaim withholding tax on foreign dividends/interest above certain amounts. Specific to each treaty — requires treaty-by-treaty analysis.

## Switzerland CGT: no tax on private securities

- **No CGT on private moveable assets** — Switzerland does not tax capital gains on private moveable assets (shares, bonds, funds) for private investors — lump-sum or not. This is a key attraction.
- **CGT on real property** — Capital gains on real property are taxed (by cantons) — even under lump-sum. See `ch-cantonal-tax`.

## Sources

- Bundesgesetz über die direkte Bundessteuer (DBG), Art. 14
- Steuerharmonisierungsgesetz (StHG), Art. 6
- ESTV (Federal Tax Administration): estv.admin.ch

> Working paper only. Lump-sum negotiations are done directly with the cantonal tax authority (Steueramt) and involve detailed negotiation. The specific canton chosen affects the outcome significantly. Engage a qualified Swiss tax adviser (Treuhänder/fiduciaire) before establishing Swiss residence.

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---

## Talk to a verified accountant

This guide is maintained by the OpenAccountants network — accountants who put
their name behind the tax answers AI gives people. The live, always-current
version (and the professional behind it) is at
[openaccountants.com](https://www.openaccountants.com).

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> **General reference only.** This document does not constitute tax, legal, or
> financial advice. Verify figures against the cited primary sources or with a
> licensed professional before relying on them.

## Today's figures and who stands behind this skill

This file is an AI skill (tax rules your AI follows) from OpenAccountants, copied on 2026-07-13. Rates, thresholds and deadlines change. For the current version of this skill, its official sources and the named accountant (if any) who stands behind it, call `get_skill` with slug `ch-lump-sum` on the OpenAccountants connector (https://www.openaccountants.com/connect), or read https://www.openaccountants.com/skills/ch-lump-sum. If neither is available, confirm every figure against the official source pages cited above before relying on it.