SWITZERLAND: An introduction to Private Wealth Law
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Overview of Switzerland's economic and political conditions
A highly attractive destination for individual relocation
Switzerland is and remains a highly attractive destination for individual relocation, thanks to a unique combination of advantages that appeal to both professionals and families:
Political and economic stability:
Switzerland’s neutral political environment, robust legal system, and AAA-rated financial sector provide a secure base for residents. Additionally, the high prosperity enjoyed locally makes Switzerland a very safe country for all its inhabitants and their assets.
Exceptional quality of life:
The country consistently ranks highly for living standards, combining safety, excellent healthcare, successful school system, in particular a unique dual education system, efficient public transportation, and clean natural surroundings.
World-class education and healthcare:
Public schooling is high-quality and largely state-funded, with many leading universities (eg, ETH Zurich, EPFL Lausanne) and a wide selection of international schools; the healthcare system is among the world’s best.
Attractive and flexible tax regimes:
Personal taxation varies by canton and municipality—some areas like Zug and selected municipalities in Ticino offer some of the lowest rates in Europe, attracting entrepreneurs, executives, and wealthy individuals.
Business and career opportunities:
Cities like Zurich, Zug, Geneva, and Basel are international business hubs, hosting major corporations, financial institutions, and vibrant startup scenes. Job markets are strong in finance, pharmaceuticals, technology, and consulting, with high salary levels and multilingual workplaces. Many regions are also very attractive for Fintech- and crypto-based companies.
Geographic and cultural diversity:
Residents enjoy a range of lifestyles, from urban and cosmopolitan (Zurich, Geneva) to Mediterranean-influenced (Ticino) or alpine retreat. The country’s central position in Europe allows quick travel to other European cities.
Open for qualified immigration:
For EU citizens, residency is straightforward due to bilateral agreements. Non-EU citizens face a more complex process but can obtain residency through investment or negotiation of tax arrangements, especially with expert guidance.
Flexible labour law and business-friendly policies:
The legal environment supports entrepreneurship and offers flexibility to both employers and employees.
Recent legislation that affects private clients
As of January 1, 2025, Switzerland enacted significant changes to its International Private Law (PILA) regarding inheritance, aimed at modernising the framework, aligning it with European (especially EU) law, and clarifying cross-border succession scenarios. Key changes/aspects affecting estates with international assets are:
Unity of succession principle continues:
The global estate (all assets, wherever located) is generally subject to one jurisdiction and one legal system, mainly based on the deceased's last domicile.
Choice of jurisdiction for international assets:
Testators can now elect to have specific assets—especially real estate located abroad—governed by the jurisdiction of the country where those assets are found. Swiss authorities can decline jurisdiction if foreign authorities where assets are located are already handling those aspects.
Foreign nationals in Switzerland may opt for jurisdiction and law of their home country for their entire estate or just part (eg, only for foreign assets), excluding Swiss jurisdiction if desired.
Conversely, Swiss nationals abroad can choose Swiss law for their estate but opt out of Swiss jurisdiction, allowing foreign authorities to oversee the estate.
Applicable law for international estates:
If the deceased resided abroad, the estate is governed by the inheritance law designated by the conflict-of-law rules of that country, not necessarily Swiss law.
Swiss dual nationals domiciled in Switzerland can now choose the law of their other nationality for their succession but must (under certain circumstances) still respect Swiss compulsory portions (forced heirship).
These options allow for partial or total subordination of the estate's administration and applicable law to the relevant foreign country, accommodating different international asset scenarios.
Increased planning options:
The new law grants more autonomy to individuals with cross-border assets, who can now fine-tune which parts of their estate are governed by which jurisdiction and legal system, making estate planning for international assets more predictable and compatible with developments like the EU Succession Regulation.
Overall, the revision enables testators to better coordinate which country’s authorities and law apply to their international assets, reducing the risk of conflicts and legal uncertainty in probate and distribution.
Revised company law:
The new company law, in force since January 1, 2023, will be fully implemented from January 1, 2025, after a two-year transition period for adapting statutes.
Changes to pension and social benefits:
AHV/IV pensions are adjusted for inflation, and the maximum contributions for Pillar 3a are increasing. It will also be possible to make retroactive contributions to Pillar 3a for up to ten years, offering tax deduction benefits.
Upcoming vote on "Initiative for a Future" ("Zukunftsinitiative Schweiz"):
The "Initiative for a Future" (officially “For a Social Climate Policy – Financed in a Fiscally Fair Manner”) is a popular initiative brought forward by young socialists ("JUSO") of Switzerland.
Key points:
Federal inheritance and gift tax of 50%: This would be an additional tax, on top of existing cantonal and communal inheritance and gift taxes.
Tax-free threshold of CHF 50 million: Only gifts and inheritances above this threshold would be taxed; the threshold applies to the deceased/donor, not the heirs/recipients.
Use of funds:
Revenues would be earmarked for ecological transformation of the economy, socially just climate initiatives, energy-efficient building renovations, retraining workers from polluting industries, and expanding public transport.
Implementation and political status:
Both Parliament and the Swiss Federal Council clearly recommend rejecting the initiative; they have not drafted a direct or indirect counterproposal.
A national vote on the initiative is scheduled for November 30, 2025.
If approved, the government would have three years to implement the initiative through appropriate regulations.
Anti-avoidance rules
The Swiss Federal Council clearly rejects the introduction of an exit tax in connection with the Initiative for a Future. In its official note, the Federal Council emphasizes:
Moving abroad from Switzerland should not automatically be considered a form of tax avoidance and be sanctioned with additional taxes.
A restriction or ban on relocating abroad is out of the question, as it would conflict with the principle of proportionality as well as constitutional and international law.
The Federal Council also explicitly rejects an exit tax aimed at securing future inheritance and gift tax revenues, stating that such a measure would be difficult to enforce and legally problematic.
The Federal Council acknowledges that it would be theoretically possible to introduce a post-move taxation right — similar to the system in Germany, where a gift made after moving abroad can still be taxed. However, it also stresses that even such a system would be difficult to implement in practice and raise legal concerns.
Even if the initiative is passed, relocating from Switzerland should not result in additional (confiscatory) taxation (unless there is a clear shift to the left in the Swiss political landscape, ie in the next election of the parliament in October 2027).
Summary:
Switzerland’s combination of stability, high living standards, education, tax efficiency, and professional opportunity continues to make it one of Europe’s and the world's top relocation destinations for individuals, entrepreneurs, and families.