The tax administration and wealthy taxpayers

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The relationship between the cantonal tax administration and wealthy taxpayers is characterised by the same pragmatism that Part B described for companies. The administration confirms the tax treatment of complex situations through advance rulings, assesses the taxpayers' returns with the benefit of detailed information and conducts audits where necessary. For wealthy taxpayers, the ruling practice provides legal certainty on questions such as the taxation according to expenditure, the treatment of trusts and foundations, the valuation of unlisted shares and the qualification of their investment activities.

The automatic exchange of financial account information, which Switzerland has practised since 2017 with a growing number of states, has changed the relationship between wealthy taxpayers and the tax authorities of their former states of residence.¹ A family that moves to Zug can no longer expect its financial affairs to remain hidden from the authorities of its home country. The Swiss banks report the accounts of foreign-resident clients, while the foreign authorities report the accounts of Swiss residents. The move to Zug is therefore a decision to be taxed in Switzerland, openly and in accordance with the law, which the practitioner's advice must reflect.

Notes

State Secretariat for International Finance, "Automatischer Informationsaustausch (AIA)", sif.admin.ch: the legal bases for the AEOI entered into force on 1 January 2017. Switzerland implements it in principle on the basis of the Multilateral Competent Authority Agreement (MCAA) and a bilateral agreement with the EU, with data collection from 2017 and the first exchanges in autumn 2018. ↩

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 September 2025.

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Dr Alexander Ressos, TEP

Rechtsanwalt/Attorney-at-Law

I am a Swiss attorney-at-law and also admitted as a solicitor in Hong Kong and in England & Wales, with almost 25 years of experience.

Together with my multilingual team, including Chinese, Japanese, Korean, Russian, Ukrainian and French native speakers, I advise companies and their owners from around the world on the full range of banking, corporate, commercial and tax law matters in Switzerland, including international tax planning, fiduciary services, and legal family office services including immigration & relocation or real estate investments. My practice has a particular focus on clients from growth and frontier markets in Greater China, Central Asia and the Caucasus, the rest of Asia, the Middle East, Africa and Latin America, and I equally advise clients from Europe and North America. Through an affiliated Swiss trust company, we also take care of the incorporation and ongoing administration of their companies and other structures, including accounting, tax returns and corporate secretarial services, and I serve as a professional director where required. With the support of a network of first-class cooperation partners, I also implement solutions worldwide.

My approach is to act as a trusted advisor who works directly with decision-makers, on an equal footing: I start from what you want to achieve and shape every structure, contract and tax decision around your commercial goals and how it improves your after-tax return. As “lawyers who make it happen”, my team and I stay involved until your company is set up, your structure is in place and your transaction has closed, and we remain available for any follow-on work that may be required. You benefit from bespoke solutions and personal attention, and sound, friendly and practical advice. We are not the lowest-cost provider in the market, nor do we intend to be; our aim is to deliver well-founded, proper solutions and excellent value for money.

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The tax administration and wealthy taxpayers

Notes

Setting up or expanding in Switzerland?