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7 French-Speaking Part of Relocation to and working in the French-speaking part of Switzerland

This publication contains general information with regard to various topics that may be of interest for Swiss and foreign high-net-worth-individuals and/or family owned businesses. For individual, case related information and enquiries, please contact one of our tax and legal specialists from the Swiss FOB & PW team.

FOB & PW SWITZERLAND Language Regions in Switzerland

SH

BS TG

ZH BL AG JU AR AI SO ZG SG

LU SZ NE NW GL

BE OW FR GR UR GR GR VD

TI GE

VS

German-speaking French-speaking Italian-speaking Rhaeto-Romanic-speaking Loyens & Loeff – FOB & PW – Zurich – 15 May 2020 - General information 2 French-Speaking Part of Switzerland – Taxation Overview (1/2)

Valais Geneva Distance to (in km) Zurich 280 280 225 Geneva 165 0 65 Next Airport International Geneva (approx. 110 min.) Geneva (approx. 10 min.) Geneva (approx. 40 min.) Private Sion (approx. 50 min.) Geneva (approx. 10 min.) Lausanne (approx. 10 min.)

Ordinary taxation (not married; no children; w/o church tax; tax rates 2020) Income tax 35.5% 45.0% 41.5% (top income tax rate; approx.) Wealth tax 0.60% 1.00% 0.79% (top net wealth tax rate; approx.)

Loyens & Loeff – FOB & PW – Zurich – 15 May 2020 - General information 3 French-Speaking Part of Switzerland – Taxation Overview (2/2)

Valais Geneva Vaud

Lump-sum taxation Lump-sum taxation requires advance tax ruling confirmation by competent cantonal tax authorities whereby full EU-citizen disclosure of all relevant facts and worldwide income / wealth position is required. Income and wealth tax basis for lump-sum taxation is subject to negotiation with competent cantonal tax authorities and depends on the facts of the case, inter alia effective worldwide income and net wealth. Income i) CHF 250k EU/EFTA i) CHF 400k EU/EFTA i) CHF 415k EU/EFTA Minimum cantonal CHF 700k non-EU/EFTA CHF 750k non-EU/EFTA CHF 1m non-EU/EFTA assessment basis ii) 7 times ii) 7 times ii) 7 times iii) 3 times iii) 3 times iii) 3 times Wealth 4x assessment basis for income, i.e. Surcharge 10% on income, i.e. Wealth included in the income tax Minimum cantonal CHF 1m EU/EFTA and CHF 440k EU/EFTA and basis assessment basis CHF 2.8m non-EU/EFTA CHF 825k non-EU/EFTA Minimum annual tax approx. CHF 100k EU/EFTA approx. CHF 170k EU/EFTA approx. CHF 170k EU/EFTA basis (approx.) approx. CHF 300k non-EU/EFTA approx. CHF 350k non-EU/EFTA approx. CHF 340k non-EU/EFTA

i) Minimum amount ii) Annual housing costs (annual rental costs or rental value) iii) Pension fee for accommodation and catering

Loyens & Loeff – FOB & PW – Zurich – 15 May 2020 - General information 4 French-Speaking Part of Switzerland – Cross-Border Commuters

France / Switzerland • Daily return to country of residence, max. 45 non-return-days ( residence certificate) • Cross-border commuters employed in Switzerland are in principle taxed at source (taxation depending on canton, see table below) • Income from self-employed activities in Switzerland is subject to ordinary Swiss income taxation based on an annual tax return (limited tax liability)

Cantons Place of Place of Taxation residence work (general rules for income from employment)

BS, BL, BE, Taxation in CH; no taxation at source in F but CH is required to pay a financial JU, NE, SO, compensation of 4.5% of the gross remuneration to F (special agreement) VD, VS Taxation in F; no taxation at source in CH but F is required to pay a financial compensation of 4.5% of the gross remuneration to CH (special agreement)

GE Taxation at source in F; CH applies exemption method (progression clause)

Taxation at source in CH (cantonal WHT tariffs A-D) but CH is required to pay a financial compensation of 3.5% of the gross remuneration to F; F grants tax credit

Other cantons Taxation at source in F; CH applies exemption method (progression clause) (e.g. ZH)

Taxation at source in CH (cantonal WHT tariffs A-D); F grants tax credit

Loyens & Loeff – FOB & PW – Zurich – 15 May 2020 - General information 5 French-Speaking Part of Switzerland - Other Aspects

Swiss migration law  Reporting procedure for max. 90 days of work in CH  Residence permit (“B-Bewilligung”), valid for 5 years, extendable  Work permit

Housing  No restrictions for purchase/construction of residential property by Swiss resident EU/EFTA citizens  Authorization required for non-Swiss resident EU/EFTA citizens and third state citizens  General restriction for purchase/construction of second homes

Swiss social security  Mandatory health and accident insurance  Pillar system (pillars 1 to 3)

Swiss gift and inheritance tax  In general no gift and inheritance taxes on transfer to spouses and children  Other parties: up to 55% depending on canton and relationship to receiving party

Loyens & Loeff – FOB & PW – Zurich – 15 May 2020 - General information 6 Disclaimer

This publication does not constitute tax or legal advice and the contents thereof may not be relied upon. Although this publication was composed with the greatest possible diligence, all entities, branch offices, partnerships, persons and practices trading under the name “Loyens & Loeff” cannot accept liability or responsibility for the results of any actions taken on the basis of this publication without their cooperation, including any errors or omissions.

Loyens & Loeff – FOB & PW – Zurich – 15 May 2020 - General information 7