Tax-Advantaged Residence, Lump-Sum Taxation and the Use of Pre-Immigration Trusts in Switzerland

Mondaq Business BriefingSwitzerland Law Articles in English (2002)

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Tax-Advantaged Residence, Lump-Sum Taxation and the Use of Pre-Immigration Trusts in Switzerland

Switzerland is certainly one of the most attractive countries in the world to live in. Its political and economic stability, combined with excellent communications and transport links, efficient public services, low tax rates and many more advantages make it the ultimate choice for business and residence. Interesting tax planning opportunities are offered by recent changes in Swiss immigration law in conjunction with the unique preferential lump-sum taxation regime available to foreigners who are not gainfully occupied in Switzerland. This makes Switzerland even more attractive as a place of residence particularly for wealthy EU citizens. Due to the absence of clear rules regarding the legal recognition and taxation of trusts, the use of trusts in the context of pre-immigration tax and estate planning offers interesting possibilities but depends considerably on whether a favourable tax ruling can be obtained from the cantonal tax authorit...

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