Wealth management in Switzerland

“Alexis, we are moving to Geneva. My children are staying in Paris. If I die there, who taxes my estate?”

Probably both countries. Since 1 January 2015, no treaty has governed inheritance between France and Switzerland : France terminated the 1953 treaty. When heirs live in France, France taxes; the canton may tax too.

Switzerland is the largest French community abroad: 168,881 French nationals on the consular register at 31 December 2025, down slightly (−2.0% over one year).

The treaty of 9 September 1966 continues to govern income and wealth tax. At Balmont Conseil, we treat a move to Switzerland as an estate planning matter as much as a tax one.

1. Why seek expert wealth management in Switzerland?

Four points, two of which are often discovered too late.

No estate tax treaty. French duties apply under domestic law, in particular Article 750 ter of the French Tax Code: an heir domiciled in France for at least six of the last ten years is taxed in France on everything they receive.
Exit tax without automatic deferral. When leaving for Switzerland, the deferral of payment must be requested, with a tax representative and guarantees put in place before departure.
The cantonal wealth tax. It applies every year to worldwide wealth, excluding property located abroad, at a rate that varies widely from one canton to another.
The canton decides a great deal. Income tax scale, wealth tax, inheritance tax between parents and children, taxation based on expenditure: everything depends on the municipality and canton chosen.

2. The France ↔ Switzerland framework in five verified points

Here is the applicable framework, checked against official sources as at 1st October 2026.

French nationals on the register	168,881 at 31 December 2025 (−2.0% over one year), the largest French community abroad.
Income tax treaty	Yes — treaty of 9 September 1966 on taxes on income and on wealth, amended by several amending protocols.
Estate tax treaty	No, since 1 January 2015. The treaty of 31 December 1953 was terminated by France. Each State applies its domestic law, with a real risk of double taxation.
Exit tax — deferral of payment	Deferral on request, with a tax representative and guarantees put in place before departure (Article 167 bis of the French Tax Code). The deferral is not automatic for Switzerland.
CSG and CRDS on property income and capital gains	7.5% for a person covered by the Swiss social security system: only the solidarity levy is due, as the CSG and CRDS exemption is open to people covered in Switzerland.

Sources: list of tax treaties concluded by France (BOI-ANNX-000306, updated 29 April 2026); exchange-of-information and recovery-assistance clauses (BOI-ANNX-000508, position at 8 October 2025); register of French nationals living outside France at 31 December 2025 (Ministry for Europe and Foreign Affairs); text of the treaty published by impots.gouv.fr; impots.gouv.fr for non-residents' social charges. Position as at 1st October 2026.

What the absence of an estate tax treaty changes. Without a treaty, no rule decides between the two States. France taxes in particular assets located in France and, under Article 750 ter, everything received by an heir domiciled in France for at least six of the last ten years. Switzerland applies the law of the deceased's canton. The tax credit for tax paid abroad, provided for by Article 784 A of the French Tax Code, does not cover every situation.

On exit tax. Guarantees must be in place before departure. This is the most frequently underestimated time constraint for an executive who holds company shares.

On taxation based on expenditure. This lump-sum regime, reserved for foreign nationals with no gainful activity in Switzerland, has been abolished in several cantons, including Zurich. It must be checked canton by canton, and it does not settle the inheritance question.

3. Our services: 360° support for expatriates and investors

Three workstreams, in the order in which they determine the others.

Exit tax and guarantees

If your securities exceed €800,000 or if you hold at least 50% of a company's profits, exit tax applies. We calculate the outstanding tax, appoint a tax representative, and prepare the necessary guarantees before your departure date.

Calculation of unrealised capital gains at the date of departure.
Deferral application, tax representative, guarantees.
Annual monitoring for as long as the deferral runs.

Passing on wealth without a treaty

We establish, asset by asset and heir by heir, who would tax your estate today, then what can be done during your lifetime to reduce the risk of double taxation: schedule of gifts, choice of investment vehicles, beneficiary clause.

A Luxembourg assurance-vie contract follows its policyholder from one country to another; its inheritance treatment must nevertheless be checked in each of the two States.

The choice of canton

Income tax, wealth tax, inheritance tax: we compare the cantons under consideration with a local adviser, on your figures, before you sign the lease or the purchase.

4. Methodology: our way of working

We work in four stages, and at each stage you know where you stand.

The initial review. We establish your actual situation: the make-up of your wealth, the project timeline, the situation of each member of the household, and the tax domicile of your heirs — because it is theirs that counts, not yours.
The applicable framework. We set out, source by source and with its date, the framework that applies to you. What we do not know, we mark “to be confirmed” — never anything else.
The choices. We present the options with figures and their respective consequences, and you decide. Wealth structuring comes after the decision, not before.
Ongoing monitoring. An annual review, free of charge, to check that the framework has not moved — treaties are amended, incentive regimes are abolished, thresholds change.

5. What the firm offers you

What concretely sets our work apart.

Sources, not claims. Every item in your file carries its reference and its date. You can check. It is the only way to work on a subject where most of the information available online is out of date.
A single point of contact in France. We coordinate your local advisers; we do not replace them: the host country's domestic tax rules are handled with a qualified professional on the ground. Our role is to keep the whole picture consistent and to defend the French side of the file.
Fees that are easy to understand. Fees disclosed before any commitment: fixed-price reviews, tailor-made engagements at €500 incl. VAT per hour, insurers' commissions on contracts taken out. The annual review is free of charge.

Frequently asked questions: Switzerland

Is there a treaty between France and Switzerland on inheritance?

No, since 1 January 2015: France terminated the treaty of 31 December 1953. Each State applies its domestic law. In France, Article 750 ter of the French Tax Code makes it possible to tax everything received by an heir domiciled in France for at least six of the last ten years.

Is the exit tax automatically deferred if I move to Switzerland?

No. The deferral must be requested, with a tax representative in France and guarantees put in place before departure (Article 167 bis of the French Tax Code). It only concerns securities portfolios worth more than €800,000 or holdings of at least 50%.

Will I pay CSG on my French rental income?

If you are covered by Swiss social security, no: you pay only the 7.5% solidarity levy on your French-source property income and property capital gains. Otherwise, the rate is 17.2%.

Does my French assurance-vie follow me to Switzerland?

The contract remains open, but its treatment in Switzerland depends on the canton and the type of contract, and its value is subject to cantonal wealth tax. Some French insurers also restrict contributions from Switzerland. We check both points before departure.

Are Swiss inheritance taxes high?

They depend on the canton: most exempt the spouse and children, a few tax them. But for a French national whose children live in France, the real issue is French: without a treaty, Article 750 ter of the French Tax Code applies as soon as the heir has been domiciled in France for at least six of the last ten years.

In summary

Switzerland does govern income tax with France, through the 1966 treaty. It has no longer governed inheritance since 2015, and the exit tax is not automatically deferred there.

A move to Switzerland is therefore prepared on two timetables: that of the exit tax guarantees, before departure, and that of the estate transfer, for as long as the heirs live in France.

Firm's fees: €500 incl. VAT per hour. Annual follow-up is free of charge.