An overview of the major changes for foreign residents settling in Switzerland in 2026: eligibility for lump-sum taxation, cantonal updates and impact of the latest international tax treaties.
Lump-sum taxation in 2026: what really changes
Since 1 January 2026, several cantons have tightened the conditions for accessing expenditure-based taxation (the so-called "forfait"). The minimum taxable threshold has been raised in five French-speaking cantons, and EU/EFTA nationals must now demonstrate wealth of at least CHF 25 million in some German-speaking cantons to qualify.
This does not spell the end of the regime, but rather an increased professionalisation of the process. A poorly framed application will be declined outright; a well-prepared one, negotiated with the administration, remains a powerful tool.
Updated tax treaties
The progressive application of the OECD multilateral instrument (BEPS Action 6) is changing the protective effect of bilateral tax treaties. The principal-purpose test (PPT) now allows tax authorities to deny treaty benefits where the main objective of an arrangement was to obtain the tax benefit itself.
In practice: structures set up without genuine economic substance become fragile. Conversely, expatriates who genuinely transfer their centre of life to Switzerland — residence, family, activity — remain protected by classic treaty rules.
Pillar 3a and revised caps
Pillar 3a contribution caps have been raised to CHF 7,258 for employees affiliated to a second pillar and CHF 36,288 for the self-employed without a second pillar. For a recently relocated expatriate, optimising pillar 3a in the first years of residence offers an often-underestimated tax lever.
Key takeaways
The Swiss tax environment remains favourable to expatriates with significant wealth, but now demands greater rigour in preparation. Three guiding principles:
- Genuine substance: the structure must reflect the taxpayer's actual life.
- Anticipation: planning should start 6 to 12 months before relocation.
- Cantonal coordination: the canton choice drives 80% of the achievable optimisation.
For a tailored review of your situation, we recommend an initial 45-minute confidential meeting.