Swiss lump-sum taxation: taxation based on expenditure

The "lump-sum tax" is the common name for taxation based on expenditure. For certain foreigners without gainful employment in Switzerland, tax is not calculated on actual income, but on lifestyle expenditure. For the 2026 federal direct tax year, this expenditure cannot be less than 435,500 francs.

This page is based on the 2026 instructions of the Federal Tax Administration (FTA) and an FTA document on personal income tax. It deals with federal tax. It does not provide figures for any canton, calculate the final tax, or address inheritance.

Federal conditions

Instructions 2026 set out several conditions for requesting taxation based on expenditure:

• to be of foreign nationality and subject to direct federal tax due to their domicile or residence in Switzerland; ;
• not to engage in any gainful activity in Switzerland, whether primary or secondary, even if the income is received abroad; ;
• to be subject for the first time, or after an absence of at least ten years.

For individuals without gainful employment and without a residence in Switzerland, tax residency begins after more than 90 days of residence. The guidelines exclude individuals residing in Switzerland solely to attend courses at an educational institution or to receive medical treatment, provided they have a residence abroad and pay ordinary taxes there.

Minimum spending in 2026

The expenditure corresponds to the standard of living of the taxpayer and their dependents, both in Switzerland and abroad. It cannot be less than the highest of three amounts:

For the 2025 tax year, the fixed floor was 434,700 francs. He therefore earns 800 francs in 2026.

How is tax calculated?

According to the 2026 instructions, the expenditure-based tax follows the standard income tax scale (formula 58c, 2026 edition). Foreign income not subject to expenditure-based tax is not included in the tax rate calculation, except in cases where a tax relief claim is filed for German, American, Austrian, Belgian, Canadian, Italian, or Norwegian taxes. The federal tax scale itself is not included here.

The relevant Swiss-source income is declared according to specific rules:

• The buildings are declared gross, without deduction of expenses or passive interest, including the rental value of the properties occupied by the owner; ;
• For movable capital, a detailed statement of securities is mandatory and only income from Swiss sources is taken into account; ;
• Annuities and pensions paid by a debtor domiciled in Switzerland are included; ;
• Property costs are deducted as actual expenses, or as a lump sum of 10 % (building ten years old or less) or 20 % (more than ten years old).

Double taxation treaties: the AFC's statement on France

Instructions 2026 specify that taxpayers can only benefit from the advantages of a tax treaty for income earned during the period when they were subject to unlimited tax liability in Switzerland. Only income from the relevant period for which, under a double taxation treaty, exemption or refund of foreign withholding taxes has been or will be claimed must be declared. Taxpayers may waive the treaty benefits, and a lump-sum credit for foreign taxes is generally not permitted against Swiss taxes, with the exception of seven countries.

For France, the instructions state that a person taxed based on expenditure "is not considered a resident of Switzerland" and cannot claim the benefits of the convention when taxed on a flat-rate basis calculated according to the rental value of the properties they own in Switzerland. The anti-abuse clauses of the convention are expressly reserved.

Regarding the text, Article 4 §6 b) of the Franco-Swiss convention of September 9, 1966, excludes from resident status any individual who is taxable in the State only on a flat-rate basis determined according to the rental value. The BOFiP (Official Bulletin of Public Finances) adds that individuals subject to federal direct tax on a flat-rate basis derived from rent, rental value, or boarding fees cannot benefit from the convention, and that the corresponding French provisions were repealed for the taxation of 2015 income. The word "expense" does not appear in the passages of the convention and the BOFiP that were consulted: the page adheres to the statement from the Federal Tax Administration (FTA) and does not draw any conclusions for your specific case.

The cantons: a changing map

The AFC document published in September 2025 (state of legislation as of January 1, 2025) states that taxation based on expenditure exists in most cantons. It is abolished in Zurich, Basel-Stadt, Schaffhausen, and Appenzell Outer Rhodes, at both the cantonal and municipal levels. Basel-Landschaft only allows it for the year of arrival.

In cantons where it is levied, the tax must not be lower than the ordinary income and wealth taxes levied on Swiss-source income and assets. In some cantons, the wealth tax is also calculated based on expenditure. The taxpayer files the required declaration and proves that they meet the conditions (Article 14 of the Federal Direct Tax Act, Article 6 of the Harmonization Act). For a specific canton, contact its tax administration: the 2026 list has not been reviewed.

Penalties for inaccurate declarations

In the event of an inaccurate or incomplete declaration, or failure to respond to a summons, a fine may be imposed. For proven tax evasion, the fine can reach the amount of tax evaded. The use of false documents is punishable by up to three years' imprisonment or a financial penalty.

Three dwellings, one floor: a numerical example (fictitious profile)

Situation. Évrard, a fictitious foreign national with no gainful employment in Switzerland, is settling in Switzerland for the first time. He requests taxation based on expenditure for the federal direct tax period, 2026. Three cases are compared: a dwelling with an annual rental value of 48,000 francs, another of 96,000 francs, and a taxpayer staying in a boarding house at 130,000 francs per year (profile assumptions).

Issue. What is the minimum expenditure to consider in each case?

Strategy. Take the highest of three amounts: 435,500 francs, seven times the rental value for a self-employed household, three times the price of the pension for other taxpayers.

Result.

The multiple of seven exceeds the floor as soon as the annual rental value exceeds approximately 62,214 francs (435,500 divided by 7).

This profile is fictitious. Rental values and pension amounts are hypothetical. The calculation sets a federal minimum: it does not specify the tax, does not indicate the cantonal minimum, and does not guarantee administrative approval.

Swiss lump sum tax: what changes depending on your case

• Your nationality and background : the condition applies to persons of foreign nationality, subject for the first time or after ten years of absence.
• Your activity : no gainful activity in Switzerland, even secondary, even if paid abroad.
• Your accommodation : the rental value or the rent determines the minimum starting from approximately 62,214 francs.
• Your canton : the flat rate is abolished in some cantons, restricted in another, and its cantonal amounts are not shown here.
• Your links with France : if you maintain links with France, the AFC's statement on the convention and anti-abuse clauses calls for personal analysis.
• Your estate France notified Switzerland, by note dated June 17, 2014, of the termination of the 1953 Convention on Successions; it ceased to have effect for the successions of persons who died on January 1, 2015.

The rule depends on your situation. No results are guaranteed.