The Swiss government has scheduled a referendum for 30 November that could reshape how large fortunes are taxed in the region. Switzerland has long been considered a safe haven for multigenerational wealth and maintains one of the lowest income tax burdens in Europe.
The proposal seeks to introduce a federal tax of 50% on inheritances and gifts exceeding CHF 50 million (approximately BRL 315 million), without exemptions for direct descendants or family-owned businesses. The measure represents a significant shift from the Swiss tradition of delegating inheritance tax matters to the cantons.
While the likelihood of approval is considered low, the mere fact that such a topic has gained traction in a historically low-tax jurisdiction has triggered uncertainty and strategic reassessments among families and ultra-high-net-worth individuals.
"Even in an unlikely approval scenario, the debate carries practical consequences: many are already reviewing corporate structures and considering alternative tax residency options," says Juliana Bhering Cabral Palhares, a partner at Bhering Cabral Advogados and an expert in estate and succession planning.
The topic resonates at a time when Brazil is also debating the taxation of significant wealth, including proposals for reforming the ITCMD and introducing taxation on exclusive funds and offshore holdings. "Although the contexts differ significantly, both countries face the shared dilemma of how to fund public policies without undermining the attractiveness of their fiscal environments," Juliana explains.
According to Brazil’s Ministry of Finance, approximately 100,000 Brazilians hold over BRL 1 trillion in assets abroad. Legal experts have advised individuals domiciled in Switzerland to simulate the impact of the proposed tax on their estate structures and to prepare wills and cross-border succession instruments in cooperation with local counsel.
"We have seen a rise in the anticipation of strategic gifts and corporate restructurings. Some clients have also begun exploring new tax residency alternatives in jurisdictions such as Italy and Uruguay," Juliana adds.