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      The long-standing non-domiciled (“Non-Dom”) tax regime was abolished as of 6 April 2025, marking the end of a system that had been in place for over two centuries. Also as per 6 April 2026, there will be relevant changes to the UK tax landscape. 

      For replacing the Non-Dom Regime, the UK introduced the 4-Year Foreign Income and Gains (FIG) regime, applying to individuals who have been non-resident in the UK for at least 10 consecutive years prior to arrival. Qualifying individuals can claim relief from UK tax for non-UK income and gains arising in the first four years of their UK tax residence.

      Hugues Salomé
      Hugues Salomé

      Partner, Head of Private Clients

      KPMG Switzerland

      Philipp Zünd
      Philipp Zünd

      Partner, Private Clients Tax

      KPMG Switzerland

      Switzerland – A stable alternative for international private clients

      For those reconsidering the UK, Switzerland offers a long-standing, rules-based alternative with strong tax certainty and quality of life. 

          The lump sum tax regime

          Available in most cantons, this special regime applies to non-Swiss nationals who do not work in Switzerland. Instead of taxing global income and assets, it uses the taxpayer’s living expenses as a surrogate tax base. 

          Factors such as the rent paid for the Swiss primary residence (or the deemed rental income in the case of ownership) are considered. Depending on the canton chosen, annual taxes under this regime can be as low as CHF 100,000, regardless of foreign income and wealth. As long as the conditions are met, a taxpayer may benefit from this regime for life.

              The ordinary tax regime

              This regime can be quite attractive due to very low income and wealth tax rates in certain cantons, along with general exemptions on gains from the disposal movable assets. In some cantons, the maximum income tax rate is in the range of 20% to 22%. 

              On top of this, a number of tax planning options are available, particularly in cross-border contexts. These may include step-up reorganizations, placing assets in trusts or other measures to structure ownership of assets in a tax-efficient manner. 

                  Gift and inheritance taxes

                  These are levied solely at the cantonal level. In all cantons, transfers to spouses are exempt, and in most cantons, transfers to children are also exempt. Some cantons do not levy gift or inheritance taxes at all.


                      For internationally mobile individuals, Switzerland’s system offers greater stability and predictability than the UK’s post-2025 rules, especially when it comes to long-term estate planning.

                          Key considerations when moving to Switzerland

                          • Immigration rules for EU/EFTA and non-EU nationals

                            Immigration rules vary by nationality:
                             

                            • EU/EFTA nationals can take up residence if they are financially independent.

                            • Non-EU/EFTA (incl. UK citizens post-Brexit) face stricter entry requirements:

                              • Over 55: must demonstrate close ties to Switzerland, sufficient financial means, Swiss health insurance, and refrain from gainful employment (except managing personalwealth).

                              • Under 55 or without close ties to Switzerland: must show a preponderant cantonal fiscal interest (often a minimum tax base/liability set by the canton) and must not engage in Swiss employment.
                          • Tax ruling

                            A cornerstone of Swiss tax planning is negotiating a tax ruling, ideally before arrival or at the very start of residence. This ruling defines the parameters of lump-sum taxation or provides clarity and legal certainty regarding the taxation of specific income and assets under the ordinary regime.

                          • Social security and wealth tax implications

                            Relocation also requires careful consideration of social security and wealth tax exposure. While coordination agreements exist between the UK and Swiss social security systems, the impact varies depending on personal circumstances.

                            Wealth tax rates differ by canton. In cases where the lump-sum regime does not apply, some cantons such as Berne and Valais offer relief measures that cap wealth tax at a fixed percentage of investment income, ensuring assets are not subject to disproportionate taxation. Other cantons have with 0.1% to 0.3% very low wealth tax rates. 
                             

                          How KPMG Switzerland can help you plan the transition

                          KPMG’s Private Client team in Switzerland works closely with the respective team in the UK to develop tailored relocation strategies. This includes negotiating tax rulings with Swiss cantons, structuring wealth, ensuring compliance with both UK and Swiss requirements, and planning for long-term asset protection.

                          Our cross-border approach covers every stage, from initial feasibility assessments to post-move compliance, helping clients make informed, confident decisions about their future tax residence.

                          Discover solutions for private clients

                          FAQs – Switzerland as an alternative to the abolished UK Non-Dom Regime

                          Yes. Individuals leaving the UK, may face an inheritance tax “tail” of up to 10-years, meaning assets remain within the scope of the UK inheritance tax long after departure. 

                          However, the UK taxation rights after leaving the UK are restricted under the UK-Switzerland Inheritance Tax Double Taxation Agreement. For example, non-UK citizens are not anymore subject to UK inheritance tax on non-UK assets as from the day of moving to Switzerland. 

                          Yes. Depending on the canton and the specific situation, the annual taxes under the lump-sum taxation can be as low as CHF 100,000. 

                          Additionally, with maximum tax rates of around 20% in some cantons and exemptions on capital gains from movable property, the ordinary taxation can also be highly attractive. 

                          If eligible (non-Swiss national, no Swiss employment), the canton agrees a living-expenses tax base (often linked to housing costs and lifestyle) in the tax ruling. 

                          Foreign income and assets are not declared in the annual tax return. The regime is indefinite while conditions are met.

                          Yes. A tax ruling can be obtained before moving to Switzerland, allowing you to know in advance how much taxes you will pay. 

                          The cantons of Schwyz and Obwalden have fully abolished gift and inheritance taxes. Furthermore, all cantons exempt transfers between spouses and most also exempt transfers to children. 

                          Planning beyond the UK Non-Dom Regime and other UK tax changes?

                          With the ongoing UK tax changes, individuals face increased tax exposure in the UK.

                          KPMG Switzerland supports you in evaluating alternative structures, relocating to Switzerland, and lump-sum rulings that ensure certainty and continuity.

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                          Meet our experts

                          Hugues Salomé
                          Hugues Salomé

                          Partner, Head of Private Clients

                          KPMG Switzerland

                          Philipp Zünd
                          Philipp Zünd

                          Partner, Private Clients Tax

                          KPMG Switzerland

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