Chapel Bridge, Lucerne, Switzerland, built in 1356
Switzerland offers a fast-track path to Swiss permanent residency for citizens of non-EU/EFTA states ready to establish an innovative Swiss start-up (here) ("owners of a Swiss company") that (i) has economic substance (ii) is innovative and (iii) contributes to the economic interests of Switzerland.
> In the canton of Lucerne, a newly established company is deemed to contribute to the economic interests of Switzerland if it has generated at least 3 new local jobs during its first two years of existence.
Citizens from non-EU countries (here) also called "third-country nationals", can apply through their prospective employer for a Swiss work permit or employment visa if (i) they have a university degree or equivalent higher education (ii) they are highly qualified (management level) (iii) they benefit from at least 5 years of relevant professional work experience (iv) they receive the same salary (here) as Swiss nationals and, most importantly (v) it can be conclusively demonstrated that no Swiss or EU national (incl. Iceland, Liechtenstein, Norway) is available for the job ("labour market testing").
Official Swiss guidance for foreigners wishing to work in Switzerland can be downloaded under this link (here).
In other words, an application for a Swiss permanent residence permit for highly skilled foreign workers requires thorough preparation: hiring the new team member must benefit the overall economic interests of Switzerland.
In the case of a multi-year stay, additional integration criteria are taken into account such as (i) professional and social adaptability (ii) language skills and (iii) age. Those factors are expected to contribute to a sustainable integration into the Swiss labor market and social environment.
> Self-employed applicants can submit an application for a Swiss employment visa themselves.
To get a work permit in Switzerland for a new employee, the employer must submit in a Swiss official language or in English:
> In Swiss professions with a pronounced shortage of skilled workers, it can be assumed that the domestic potential has been exhausted and there is no need for Steps 4 to 8 above. It is the responsibility of the applicant to explain the nature of the shortage and the authorities have discretion as to whether the domestic potential has been exhausted. Temporary fluctuations due to the economic situation do not constitute a shortage of skilled workers.
As at 01.02.2023, the following professions (here) experienced a pronounced shortage of skilled workers in Switzerland:
To get a Swiss work permit, the highly-skilled candidate must provide:
> Before they can start their new Swiss employment, successful candidates must register with the Residents Registration Office ("Einwohnerkontrolle") of their municipality within 14 days after their arrival in Switzerland.
> In addition, they must take out
health insurance
for themselves and their family
no later than 3 months
after arriving in Switzerland.
Promoter | Business Development Lucerne |
---|---|
Competent authorities on cantonal level | Cantonal Migration Office |
Competent authorities on federal level | State Secretariat for Migration (SEM) |
Yearly quotas | 70 - 90 places per year |
The decisive factor to determine if a person must pay taxes in Switzerland is the person's domicile.
Pursuant to Art. 23 para. 1 of the Swiss Civil Code (here), a person’s domicile is the place in which s/he resides with the intention of settling. Contrary to public opinion, a person can have no more than one domicile at a time, at least according to Swiss law (Art. 23 para. 2 CC).
The intention of staying permanently (that is, of settling) is measured by a set of key factors, laid out in Art. 4 of the OECD Model Convention (here), which in their totality contribute to determine a person's centre of vital interests:
However, a place of work taken alone, does not qualify as a tax domicile.
As a general rule, an individual already establishes tax residence in Switzerland, irrespective of short interruptions, if a stay of a minimum of 30 days is combined with a gainful activity, or without such activity if the stay lasts a minimum of 90 days.
On the other hand, an individual who is domiciled abroad, but stays in Switzerland solely for educational or health reasons, is not deemed to be resident in Switzerland for tax purposes.
Legal Form | Key Features |
---|---|
GmbH | CHF 20,000 share capital |
AG | CHF 100,000 share capital |
Public disclosure of shareholder | |
GmbH | Yes |
AG | No |
Residence of director | Switzerland (mandatory) |
Swiss companies with an annual turnover above CHF 100,000 must register with the Federal Tax Administration - FTA (here), file quarterly VAT returns, and remit (or reclaim) VAT within 60 days after the end of a quarter (here).
You will find everything you need to know about Swiss VAT under this link (here).
Switzerland levies a standard VAT rate of 7.7% applying to (i) the supply of goods and services within Switzerland and Liechtenstein and (ii) the import of goods and services into Switzerland.
> Exports of goods and services are zero rated.
> Since 2019, Swiss businesses (with a global turnover above CHF 500,000) are subject to a radio and TV fee between CHF 365 and CHF 35,590 based on the previous year's turnover - tariff categories (here).
> The official Swiss VAT number of a company (which also serves as its registration number) has the following format: CHE-187.974.011
Swiss Canton | Lowest Rate | Highest Rate | Main Town |
---|---|---|---|
Lucerne | 11.20% | 13.20% | 12.20% |
Zug | 11.80% | 12.20% | 11.90% |
Schwyz | 11.80% | 14.40% | 14.10% |
Nidwalden | 12.00% | 12.00% | 12.00% |
Thurgau | 12.20% | 13.90% | 13.20% |
Glarus | 12.50% | 12.70% | 12.50% |
Schaffhausen | 12.50% | 14.50% | 13.80% |
Uri | 12.60% | 13.40% | 12.60% |
Fribourg | 12.70% | 14.70% | 14.10% |
Appenzell Inner-R. | 12.70% | 12.70% | 12.70% |
Obwalden | 12.70% | 12.70% | 12.70% |
Basel-City | 13.00% | 13.00% | 13.00% |
Appenzell Outer-R. | 13.00% | 13.00% | 13.00% |
Vaud | 13.20% | 14.10% | 14.00% |
Neuchatel | 13.60% | 13.60% | 13.60% |
Geneva | 13.60% | 14.10% | 14.00% |
Solothurn | 13.80% | 16.30% | 15.30% |
St. Gallen | 14.30% | 14.30% | 14.30% |
Grisons | 14.80% | 14.80% | 14.80% |
Jura | 15.30% | 16.70% | 16.00% |
Basel-Country | 15.90% | 15.90% | 15.90% |
Aargau | 16.30% | 16.30% | 16.30% |
Valais | 17.00% | 17.10% | 17.10% |
Ticino | 17.10% | 19.50% | 19.20% |
Zurich | 17.40% | 20.30% | 19.70% |
Berne | 19.40% | 22.80% | 21.00% |
Source: NZZ |
Income tax (progressive rate) | 15 - 25% (average rate) |
---|---|
Wealth tax (only net worth over CHF 100,000) | From 0.13% (in Nidwalden) to up to 1% (in Geneva) [see comparative chart below] |
Capital gains (from shares, bonds) | Tax exempt in Switzerland |
> If a dividend recipient owns over 10% of the payor company’s share capital, then only 60% of such dividends are taxable.
Switzerland levies an annual individual net wealth tax varying from 0.13% to 1% depending on the Swiss canton and commune (see Swiss wealth tax rates below).
The Swiss wealth tax (official guidance here) is calculated on the fair market value (as at 31 December) of all worldwide assets minus all worldwide debts:
> Worldwide debts (e.g. mortgages or other loans) are fully deductible.
> Foreign real estate is only considered for determining the Swiss wealth tax rate (which is progressive) but is exempted from the tax itself.
> Swiss real estate is taxed at the normally lower tax rate as determined by the cantonal tax authorities where the property is located.
> Leased assets, pension entitlements (Swiss and foreign) and household goods (furniture, clothes) are exempted from Swiss wealth taxation.
> Wealth of spouses and minor children are added to the overall tax base (joint filing and taxation).
> Swiss wealth tax also applies to individuals benefitting from the Swiss lump-sum tax regime (here) and the Swiss cantons apply different calculations methods.
Swiss canton | Maximum tax (main town) |
---|---|
Nidwalden | 0.13% |
Obwalden | 0.14% |
Uri | 0.20% |
Solothurn | 0.21% |
Schwyz | 0.23% |
Appenzell Inner-Rhodes | 0.25% |
Lucerne | 0.26% |
Zug | 0.28% |
Thurgau | 0.29% |
Grisons | 0.32% |
Glarus | 0.35% |
Appenzell Outer-Rhodes | 0.41% |
Saint Gall | 0.44% |
Aargau | 0.44% |
Schaffhausen | 0.47% |
Jura | 0.57% |
Ticino | 0.58% |
Berne | 0.58% |
Fribourg | 0.60% |
Valais | 0.63% |
Zurich | 0.66% |
Neuchatel | 0.68% |
Basel-Country | 0.76% |
Vaud | 0.79% |
Basel-City | 0.80% |
Geneva | 1% |
A Swiss federal withholding tax of 35% is levied on:
> For Swiss resident taxpayers, the withholding tax is fully credited against their Swiss tax liability.
> A foreign recipient of interest and dividends may be granted a full or partial refund if a double tax treaty (DTT) exists between Switzerland and the recipient’s country of residence - Switzerland currently has DTTs with over 100 countries (here). Double taxation treaties limit the maximum withholding tax that can be collected by the contracting states (known as "residual tax").
Most people do not leave instructions about who should receive their wealth upon death. In fact, 75% of all Swiss inheritance cases lack a will. In such instances, the statutory rules of Swiss inheritance law find application.
The division of the estate depends on which relatives the deceased person leaves behind. Some relatives known as forced heirs (the surviving spouse or registered partner, the children or, only if there are no children, the parents) are entitled to a minimum portion of the estate, the forced heirship share (the so-called "Pflichtteil" or compulsory part). The forced heirship share provides a minimum protection that cannot be defeated by will.
Currently, the forced heirship share of a descendant amounts to 75% of his statutory share of the estate ("gesetzlicher Erbanteil"), defined as the share of the estate provided by law in the absence of a will.
The difference between the statutory share and the forced heirship share is the free quota ("verfügbare Quote"), which is freely attributable by means of a will to whomever the testator chooses (see table below).
In its 2015 report Modernization of Family Law (here), the Swiss Federal Council found that current Swiss inheritance law dating back to 1907 does not reflect the needs of the family of the 21st century and proposed to make it more flexible by increasing the free quota. Most importantly, starting from 1 January 2023, the testator has more freedom to dispose of his property via a will, for example by favoring the actual life partner (who has no share of the estate under Swiss law), a stepchild or, alternatively, the child who is prepared to run the family business - to the detriment of the deceased person's other children and parents.
The main innovations of the new Swiss inheritance law are:
This has beneficial consequences for Swiss business succession planning. In fact, Swiss entrepreneurs will henceforth be able to attribute the free quota to the child effectively running the family enterprise. This decreases the risks of having to break up (or liquidate) the family company in order to pay out the respective share in the Swiss company's market value to the other entitled children.
Similarly, the new Swiss succession law introduces the concept of so-called
deferred entitlements. Thus, if a large part of the deceased person's asset is vested in company assets, legal pay-outs to heirs may henceforth be delayed and disbursed in the form of successive dividend payments.
Deceased leaves behind | Current law | New law (2023-) | ||||
---|---|---|---|---|---|---|
Statutory Share | Forced Heirship Share | Free Quota | Statutory Share | Forced Heirship Share | Free Quota | |
ONLY descendants | 100% | 75% | 25% | 100% | 50% | 50% |
ONLY spouse (or registered partner) | 100% | 50% | 50% | 100% | 50% | 50% |
ONLY parents | 100% | 50% | 50% | 100% | 0% | 100% |
ONLY siblings or their descendants | 100% | 0% | 100% | 100% | 0% | 100% |
Descendants AND spouse | 50% AND 50% | 37.5% AND 25% | 37.5% | 50% AND 50% | 25% AND 25% | 50% |
Parents AND siblings AND spouse | 12.5% AND 12.5% AND 75% | 6.25% AND 0% AND 37.5% | 56.25% | 12.5% AND 12.5% AND 75% | 0% AND 0% AND 37.5% | 62.5% |
Parents AND spouse | 25% AND 75% | 12.5% AND 37.5% | 50% | 25% AND 75% | 0% AND 37.5% | 62.5% |
Parents AND siblings | 50% AND 50% | 25% AND 0% | 75% | 50% AND 50% | 0% AND 0% | 100% |
Siblings AND spouse | 25% AND 75% | 0% AND 37.5% | 62.5% | no changes |
Spouses | Tax exempt |
---|---|
Children, grandchildren | Tax exempt (0 - 3.5% if the testator’s last domicile was in the canton of Appenzell Inner-Rhodes, Lucerne, Neuchatel, or Vaud) |
Parents | 0 - 15% (the last domicile is relevant) |
An individual becomes liable to Swiss cantonal gift or inheritance tax upon:
> Swiss gift and inheritance taxes are due in the canton of the donor or deceased. The residence of the receiver is irrelevant for Swiss tax purposes.
> In fact, the Swiss inheritance and gift taxes are cantonal taxes. The Swiss federal government does not levy any inheritance or gift taxes. A detailed overview of the applicable cantonal tax rates is available (here) and below.
> The cantons of Obwalden and Schwyz do not levy any gift or inheritance taxes at all, whereas the canton of Lucerne does not levy any gift taxes at all.
> Interestingly, Swiss gift and inheritance taxes are not covered by Switzerland's famous lump-sum tax regime ("Pauschalbesteuerung") and the normal cantonal tax rules find application. The only exceptions are the cantons of Geneva and Jura who both levy a special tax on gifts and estates accruing to children of "lump-sum individuals".
Last domicile of donor / deceased | Spouses | (Grand-) Children | Parents | Siblings | Other persons |
---|---|---|---|---|---|
Aargau | exempt | exempt | exempt | 6 - 23% (no allowance) | 12 - 32% (no allowance) |
Appenzell Inner-Rhodes | exempt | 1% (only contributions above CHF 300,000) | 4% (only contributions above CHF 20,000) | 6% (only contributions above CHF 5,000) | max 20% (only contributions over CHF 5,000) |
Appenzell Outer-Rhodes | exempt | exempt | exempt | 22% (only contributions above CHF 5,000) | max 32% (only contributions above CHF 5,000) |
Basel-City | exempt | exempt | 5 - 11% (no allowance) | 7.5 - 16.5% (no allowance) | 22.5 - 49.5% (no allowance) |
Basel-Country | exempt | exempt | exempt | 15% (only contributions above CHF 30,000) | 30% (only contributions over CHF 10,000) |
Berne | exempt | exempt | 6 - 15% (only contributions above CHF 12,000) | 6 - 15% (only contributions above CHF 12,000) | max 40% (only contributions over CHF 12,000) |
Fribourg | exempt | exempt | exempt | 5.25% (only contributions above CHF 5,000) | max 22% (only contributions above CHF 5,000) |
Geneva | exempt | exempt | exempt | 6 - 12% (no allowance) | max 26% (no allowance) |
Glarus | exempt | exempt | 2.63 - 6.56% (only contributions above CHF 50,000) | 4.2 - 10.5% (only contributions above CHF 10,000) | max 26.2% (only contributions above CHF 10,000) |
Grisons | exempt | exempt | exempt | 5% (only contributions above CHF 7,000) | 15% (only contributions above CHF 7,000) |
Jura | exempt | exempt | 7% (no allowance) | 14% (no allowance) | max 35% (no allowance) |
Lucerne | exempt | exempt (gift tax) | 0 - 2% (inheritance tax) | exempt (gift tax) | 6-12% (inheritance tax) | exempt (gift tax) | 6-12% (inheritance tax) | exempt (gift tax) | max 40% (inheritance tax) |
Neuchatel | exempt | 3% (no allowance for gift tax) | allowance of CHF 50,000 for inheritance tax | 3% (no allowance for gift tax) | allowance of CHF 50,000 for inheritance tax | 15% (no allowance) | max 45% (no allowance) |
Nidwalden | exempt | exempt | exempt | 5% (only contributions above CHF 20,000) | max 15% (only contributions above CHF 20,000) |
Obwalden | exempt | exempt | exempt | exempt | exempt |
Schaffhausen | exempt | exempt | 2 - 8% (only contributions above CHF 30,000) | 4 - 16% (only contributions above CHF 10,000) | max 40% (only contributions above CHF 10,000) |
Schwyz | exempt | exempt | exempt | exempt | exempt |
Solothurn | exempt | exempt | exempt | 4 - 10% (only contributions above CHF 14,000 but no allowance for inheritance tax) | 12 - 30% (only contributions above CHF 14,100 but no allowance for inheritance tax) |
Saint Gall | exempt | exempt | 10% (only contributions above CHF 25,000) | 20% (only contributions above CHF 10,000) | max 30% (only contributions above CHF 10,000) |
Thurgau | exempt | exempt | 2 - 7% (only contributions above CHF 20,000) | 4.1 - 14% (no allowance) | max 28% (no allowance) |
Ticino | exempt | exempt | exempt | 5.9 - 15.5% (no allowance) | max 41% (no allowance) |
Uri | exempt | exempt | exempt | 8% (only contributions above CHF 15,000) | max 24% (only contributions above CHF 15,000) |
Valais | exempt | exempt | exempt | 10% (no allowance) | max 25% (no allowance) |
Vaud | exempt | 0.01 - 3.5% (no allowance) | 2.6 - 7.5% (no allowance) | 5.3 - 12.5% (no allowance) | max 25% (no allowance) |
Zug | exempt | exempt | exempt | 4 - 8% (no allowance) | max 20% (no allowance) |
Zurich | exempt | exempt | 2 - 6% (only contributions above CHF 200,000) | 6 - 18% (only contributions above CHF 15,000 | max 36% (no allowance) |
Real estate transfer tax | 1 - 3% (depending on the canton) |
---|---|
Capital gains tax | 25 - 50% discount if under 5-year holding period |
Examination period | 2 - 4 months |
---|---|
L Permit issued | Valid for 1 year |
L Permit renewed | Valid for 1 year |
B Permit issued | Valid for 5 years |
C Permit issued | Permanent Swiss residence (eligible after 5 years for EU/EFTA citizens and 10 years for the rest of the world) |
Swiss passport | Elegible after 12 years of residence (L Permit years are not counted) |
Under the Swiss investor visa program, Swiss citizenship is possible after 12 years, as years spent under Permit L are not counted. On the other hand, years spent in Switzerland between the age of 8 and 18 are counted twice.
Demonstrated social integration and medium skills in a Swiss national language (German, French, Italian) is required, that is, B1 oral skills and A2 writing skills as per the Common European Framework of Reference (CEFR).
> Overall, 12 years until naturalization as a Swiss citizen (here) under the Swiss investor visa program is the longest waiting period when comparing it to other residency by investment plans:
> The application for Swiss citizenship must be filed with the cantonal authorities of the applicant's Swiss place of residence.
___________________________________________
Useful Links: Swiss Personal Tax
Federal Tax Administration (FTA) (2018) How to Fill Out a Swiss Tax Declaration (here) [in German only]
FTA (2020) Essential Features of the Swiss Tax System (here) [in German only]
FTA (2021) Personal Income Tax in Switzerland (here) [in German only]
FTA (2021) Personal Wealth Tax in Switzerland (here) [in German only]
FTA (2019) Federal Withholding Tax in Switzerland (here) [in German only]
FTA (2020) Inheritance and Gift Tax in Switzerland (here) [in German only]
FTA (2019) Real Estate Tax in Switzerland (here) [in German only]
FTA (2022) Real Estate Transfer Tax in Switzerland (here) [in German only]
FTA (2020) Taxation of Real Estate Gains in Switzerland (here) [in German only]
Zurich
Astrantia Consulting Ltd
Schützengasse 25
8001 Zurich
Switzerland
+41 44 700 28 88