Location
Tax Advisory Services
- Advisory on Corporate Taxation regimes
- Advisory on Personal Taxation regimes
- Advise on tax favourable Solutions
- Advisory on Double Taxation (Avoidance) Agreements
- Negociate Tax Rulings with Tax Authorities
- Advisory on Lump Sum tax regime for HNW-, UHNW- and/or High/Very High Net Income individuals
The UK's remittance based non-dom tax regime will be abandoned on Aprilt 6, 2025. This will have significant consequences for the current non-doms, both for Income Tax, but above all for Inheritance Tax. In 2013 an estimated 115'000 people had a non-dom statust, in 2024 this is less than 70'000. The annual non-dom tax had been increased in 2015 to GBP 90'000.
Relocation to Switzerland and applying for the Lump Sum tax regime, will conserve these tax benefits, both for Income tax and Inheritance tax. Inheritance tax and Gift tax are not levied for first degree relatives in Switzerland. The Lump Sum tax is levied based on the synthetically computed individual's cost-of-living at the locus of domicilation and asset tax on net assets value in Switzerland. While the non-dom tax regime in the UK had been granted for a maximum of 15 years, the Swiss Lump Sum tax regime is granted on a lifetime based tax ruling, ceteris paribus. Subject to the tax ruling, it is not allowed for both husband and wife to have Income from employment in Switzerland. It should be noted that Swiss legislation is characterized by a history of legal consistency and legal certainty. The first Lump Sum tax regime was introduced in 1862 by the Canton of Vaud and applicable in all Cantons by 1948. The Federal State introduced the Lump Sum Tax regime in 1934. The Swiss Lump Sum tax regime has been recognised in Double Taxation (avoidance) Agreements with all applicable foreign countries. Some 4'500 HNW-, UHNW- and High Income individuals have been granted a Lump Sum tax ruling in Switzerland as at now.
The Italian Lump Sum tax regime is applicable for 15 years only. Italy introduced the Lump Sum Tax regime in 2016. The annual tax has been doubled in August, 2024 to EUR 200'000. In specific cases Italy may be an option as destination to relocate for some current non-dom individuals.