Swiss lump-sum taxation: the forfait, canton by canton

What is actually true

• Three cumulative conditions, and all three are absolute. You must not be a Swiss citizen; you must be taking up Swiss tax residence for the first time or after at least ten years of absence; and you must not carry on any gainful activity in Switzerland. Managing your own private assets and earning income abroad are permitted. For married couples both spouses must independently satisfy all three — a Swiss-citizen spouse defeats the regime for the household.
• The right lapses the moment you acquire Swiss citizenship or take up employment in Switzerland. The forfait and naturalisation are mutually exclusive, which matters for anyone treating Switzerland as a passport path rather than a residence.
• The tax base is deemed annual living expenditure, subject to floors: it cannot be less than seven times the annual rent or rental value of the primary residence (three times the pension price for hotel-based residents), nor less than the taxpayer's actual worldwide living expenses, nor less than the statutory minimum. The federal minimum taxable base is CHF 434,700. That base is then taxed at ordinary federal, cantonal and communal rates — the forfait changes what is taxed, not the rate applied.
• Cantons set their own, higher minimums, and this is where the real negotiation happens. Cantonal minimums generally run from roughly CHF 400,000 to CHF 600,000 and above, with EU/EFTA nationals often facing a lower entry point than third-country nationals. A federal wealth-tax equivalent is also computed in most cantons on a multiple of the expenditure base.
• Five cantons have abolished the regime outright: Zurich (by popular vote in 2009, effective January 2010), Schaffhausen, Appenzell Ausserrhoden, Basel-Landschaft and Basel-Stadt. Four more — Thurgau, St Gallen, Lucerne and Bern — retained it with tightened conditions. The regime survives in the remaining cantons, with Vaud, Valais, Ticino, Geneva, Zug, Schwyz, Grisons, Obwalden and Nidwalden the ones actually used at scale.
• It is a small, visible population. Fewer than 0.1% of Swiss taxpayers are taxed on an expenditure basis; at the end of 2018 the figure was 4,557 people, generating CHF 821 million in tax. This is not a mass-market regime, and it has survived two national abolition attempts precisely because that revenue figure is defensible.

Jurisdiction by jurisdiction

Switzerland — federal floor low

Federal minimum taxable base CHF 434,700, or seven times rent/rental value of the main residence, or actual worldwide living expenses — whichever is highest. Taxed at ordinary rates. The federal floor is the starting point, not the answer; the cantonal floor is almost always higher.

Switzerland — Vaud, Valais, Ticino, Geneva medium

The cantons where the forfait is genuinely used at scale for UHNW arrivals. Cantonal minimum expenditure bases broadly in the CHF 400,000–600,000+ range, negotiated in a binding advance ruling with the cantonal administration before you move. Actual all-in annual tax commonly lands in the low-to-mid six figures CHF, but is entirely canton- and commune-specific.

Switzerland — Zurich, Basel-Stadt, Basel-Landschaft, Schaffhausen, Appenzell Ausserrhoden high

Abolished. Zurich by referendum in 2009 (effective January 2010); the other four followed. Federal lump-sum taxation technically remains available to a resident of these cantons but is pointless, because full ordinary cantonal and communal taxation applies on worldwide income and wealth.

Switzerland — Thurgau, St Gallen, Lucerne, Bern medium

Retained the regime but tightened the conditions and raised the floors relative to the classic cantons. Available, but generally not competitive against Vaud, Valais or Ticino for a family with a real choice.