Switzerland: A Private Wealth Law Overview

Introduction to and Overview of Switzerland's Economic and Political Conditions

Switzerland remains a highly attractive relocation destination, thanks to a unique combination of advantages appealing 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. The high local prosperity makes Switzerland a very safe country.
• Exceptional quality of life: Switzerland consistently ranks highly for living standards, combining safety, excellent healthcare and a successful school system with a unique dual education model, efficient public transportation and clean, natural surroundings.
• World-class education and healthcare: Public schooling is high quality and largely state-funded, with leading universities and many international schools; healthcare 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 start-up scenes. Job markets are strong in finance, pharmaceuticals, technology and consulting, with high salaries and multilingual workplaces. Many regions are also attractive for fintech and crypto companies.
• Geographic and cultural diversity: Residents enjoy lifestyles from urban and cosmopolitan (Zurich, Geneva) to Mediterranean-influenced (Ticino) or alpine retreat. Switzerland’s central European position allows quick travel to other major 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 tax arrangements, especially with expert guidance.
• Flexible labour law and business-friendly policies: The legal environment supports entrepreneurship and offers flexibility for employers and employees.

Recent Legislation That Affects Private Clients

Introduction of the Act on the Transparency of Legal Entities and the Identification of Beneficial Owners (TJPG)

On 26 September 2025, the Swiss Parliament adopted the TJPG, creating a central non-public federal register of ultimate beneficial owners. The reform strengthens Switzerland's anti-money laundering framework and aligns it with international standards.

The TJPG applies to Swiss legal entities and foreign entities with a sufficient nexus to Switzerland, such as effective management, Swiss real estate or a branch. Swiss-based trustees not covered by the Anti-Money Laundering Act must identify and retain beneficial owner information, though this is not reported to the register. Exemptions include listed companies (and majority-owned subsidiaries), certain pension institutions, foundations and associations.

Entities must identify, verify, document and report ultimate beneficial owners, including full chains of control in complex structures, and update information within one month of changes. The framework also introduces notification and co-operation duties for equity stakeholders, beneficial owners and third parties involved in the chain of control. A supervisory body oversees compliance and may impose sanctions, including suspension of participation or financial rights or, in severe cases, dissolution. Intentional violations may result in fines up to CHF500,000. The regime is expected to take effect in the second half of 2026.

Individual taxation initiative approved

On 8 March 2026, the Swiss electorate approved the Act on Individual Taxation, replacing the previous system under which the income and assets of spouses in an unseparated marriage were accumulated for tax purposes. This had long been criticised for creating a "marriage penalty", as progressive tax rates did not always offset the effects of accumulation, meaning some married couples were taxed more heavily than comparable unmarried couples. The Federal Supreme Court had already declared this outcome unconstitutional in 1984. Under the new system, each individual will be taxed separately on their income and assets and must file an individual tax return, regardless of marital status.

The reform introduces several changes. At the federal level, a single standard tariff will apply to all taxpayers, while cantons retain authority over their own tax rates and deductions. Income from employment, pensions, etc, will be allocated to the earning spouse, while income from assets will be attributed to the owner of the asset. Assets will generally be allocated according to civil law ownership. Debts and debt interest will be attributed to the debtor under the relevant contract.

Child-related deductions, as well as the income and assets of minor children, will generally be split equally between parents with shared parental custody. Procedural rights and obligations will also apply individually, abolishing the spouses' mutual right to inspect each other's tax files and their joint and several liability for tax debts.

Eligibility for lump-sum taxation will be assessed separately for each spouse. As minimum thresholds will apply per person rather than per couple, this may increase the tax base and overall tax burden in certain cases. While the reform is expected to ease the burden for many dual-income households, traditional single-earner families, particularly higher-income households, may face higher taxation. As spouses have historically been taxed jointly, allocating income, assets and debts may create practical challenges when filing the first individual tax returns. The new regime is not expected to enter into force before 2030 and must be implemented by 2032 at the latest.

Initiative to abolish the taxation of the imputed rental value approved

In a vote on 28 September 2025, the abolition of the imputed rental value was approved, fundamentally reforming the taxation of owner-occupied residential property. Homeowners were previously taxed on a notional rental income reflecting the rent theoretically earned from the property, while mortgage interest and certain maintenance costs were generally deductible.

Under the new framework, owner-occupied residential property will no longer generate taxable imputed income. At the same time, mortgage interest deductions relating to such property will be abolished, except for a deduction for first-time buyers of a primary residence over a ten-year period. Maintenance costs will generally no longer be deductible, with limited exceptions (eg, historic buildings and, depending on the canton, energy-efficiency measures). Cantons may also introduce special taxes on second homes.

The reform, expected to enter into force no earlier than 2028, is likely to benefit homeowners with low mortgage debt, while highly leveraged buyers or owners of renovation-intensive properties may face less favourable outcomes.

"Initiative for a Future" rejected

The Swiss electorate, on 30 November 2025, rejected the proposal for a 50% federal tax on inheritances and gifts exceeding CHF50 million, leaving the existing cantonal and municipal framework unchanged.

Crypto tax transparency: CRS 2.0 and CARF

The OECD's Crypto-Asset Reporting Framework (CARF) and Common Reporting Standard (CRS) 2.0, effective 1 January 2026, extend global tax reporting to crypto-assets, e-money and central bank digital currencies. Switzerland is expected to exchange 2027 data in 2028, marking the end of crypto privacy for tax purposes and increasing authorities' ability to detect undeclared holdings and gains.

Revised Private International Law Act (PILA) rules on successions

The 2025 revision enhances autonomy for cross-border estates by expanding options for choosing jurisdiction and applicable law, reducing jurisdictional conflicts and legal uncertainty.

Summary

Switzerland’s combination of stability, high living standards, education, tax efficiency and professional opportunity continues to make it one of the world's top relocation destinations.