Relocating families and wealth to Switzerland today

From asylum to residence permit

The Locarnese of 1555 moved to Zurich because they had no choice. Wealthy families who move to Switzerland today usually do so by choice, for reasons of security, tax, education, quality of life or the proximity of their banks and advisers. The legal questions they face are nevertheless structurally similar to those of the sixteenth century. A family that relocates needs a right of residence, it must know how it will be taxed, it may want to acquire citizenship in due course and it must decide how to hold and transmit its assets across generations. The sixteenth-century distinction between protection and citizenship survives in modern form in the distinction between a residence permit, which can be granted quickly, and naturalization, which requires many years of residence and integration. The following subsections survey the principal instruments from a practitioner's perspective. The taxation of Italian families in Ticino, including the Italian flat tax for new residents, is discussed in Chapter E.V, and the relocation of Italian entrepreneurs in Chapter H.II.

Residence for persons without gainful activity

Nationals of member states of the European Union and of the European Free Trade Association who do not work in Switzerland obtain a residence permit under the Agreement on the Free Movement of Persons if they have sufficient financial means and health and accident insurance covering all risks. The permit (B EU/EFTA) is not subject to quotas.¹ For nationals of other states the Federal Act on Foreign Nationals and Integration (FNIA, SR 142.20) and its implementing Ordinance on Admission, Period of Stay and Employment (OASA, SR 142.201) provide two main routes. Under Art. 28 FNIA, foreign nationals who are no longer gainfully active may be admitted if they have reached the minimum age set by the Federal Council, have special personal ties to Switzerland and possess the necessary financial means. Art. 25 OASA fixes the minimum age at 55 years and specifies that special personal ties exist in particular where the applicant has spent longer periods in Switzerland, for instance for holidays, education or work, or has close relatives in the country.² The applicant may not pursue gainful activity in Switzerland or abroad, with the exception of the management of his or her own assets.

For younger applicants from third states, the cantons may grant a residence permit on the basis of important public interests under Art. 30(1)(b) FNIA in conjunction with Art. 32 OASA, which allows admission for important fiscal reasons. In practice this route is used for wealthy individuals who will pay substantial taxes, often under the lump-sum regime described below. The cantonal authorities examine the application and forward it to the State Secretariat for Migration (SEM), whose approval is required.³ Each canton sets its own expectations as to the minimum tax revenue that justifies a permit on fiscal grounds, and the practice of Ticino differs from that of Geneva, Vaud, Valais, Zug or Graubünden.⁴ The fiscal-interest permit is the modern counterpart of the selective admission policy of the early modern Swiss cities, which welcomed newcomers whose skills or capital served the common good and restricted those who might compete with established citizens.

Notes

1. Kanton Appenzell Innerrhoden, Amt für Wirtschaft and Kantonale Steuerverwaltung, Merkblatt Bewilligungsprozess Pauschalbesteuerung, https://www.ai.ch/themen/steuern/publikationen/merkblaetter/merkblatt-bewilligungsprozess-pauschalbesteuerung.pdf/@@download/file/Bewilligungsprozess%20Pauschalbesteuerung.pdf (consulted 4 October 2026): for EU/EFTA nationals without gainful activity, "ausreichende finanzielle Mittel und eine alle Risiken abdeckende Kranken- und Unfallversicherung", permit B EU/EFTA, no quota. Legal basis: Agreement of 21 June 1999 between the Swiss Confederation and the European Community and its Member States on the Free Movement of Persons (AFMP), SR 0.142.112.681, Annex I, Art. 24(1), https://www.droit-bilingue.ch/de-fr/0.1/0.14/0.142.112.681-annexI-lvlu1-lvlV-24-52.html (consulted 5 October 2026): "ausreichende finanzielle Mittel" and a health insurance "der sämtliche Risiken abdeckt". ↩
2. Omnilex, commentary page on Art. 28 AIG, https://app.omnilex.ai/de/sources/commentaries/ch-fedlex--142.20--28 (consulted 4 October 2026), quoting Art. 28 AIG and Art. 25 VZAE (minimum age 55; longer earlier stays; close relatives; financial means above the threshold for supplementary benefits; no gainful activity except the management of one's own assets). Federal Act on Foreign Nationals and Integration of 16 December 2005 (FNIA), SR 142.20; Ordinance on Admission, Period of Stay and Employment of 24 October 2007 (OASA), SR 142.201. ↩
3. Kanton Appenzell Innerrhoden, Merkblatt Bewilligungsprozess Pauschalbesteuerung (above): residence permits for third-country nationals under 55 under Art. 32 VZAE "aus wichtigen fiskalischen Gründen"; approval by the SEM. ↩
4. Cantonal minimum tax expectations for permits on fiscal grounds are not published uniformly. ↩

For general information only. This article does not constitute legal or tax advice, does not replace advice on an individual case and creates no lawyer-client relationship. It reflects the legal position as of August 2025.