Families who treat a Swiss move as a single product are mixing two systems. Swiss forfait versus ordinary tax is a choice of assessment method, where the canton still offers the choice, not a secret federal tariff and not a residence permit. Expenditure-based taxation (Besteuerung nach dem Aufwand, imposition d’après la dépense) taxes certain foreign nationals on worldwide living costs, subject to statutory floors and a control calculation. Ordinary taxation taxes worldwide income, and cantonal wealth, under the ordinary rules. They are not available identically in every canton, and the 2010s federal tightening still frames the 2020s file.
This article is general information for families considering a move. It is not a tax ruling, a mandate, or personalised advice. Eligibility, the expenditure base, and cantonal practice depend on the facts and on Swiss counsel who can read the file against the federal acts, the FTA materials, and the canton of intended residence.
Swiss forfait versus ordinary tax is a method, not a secret tariff
The Federal Department of Finance describes the regime on its lump-sum taxation page. Expenditure-based taxation is a simplified assessment of income, and at cantonal level of wealth, for foreign nationals who become Swiss tax-domiciled for the first time or after at least ten years outside the country, and who are not gainfully employed in Switzerland. Regular tax rates still apply to the assessed base. The method changes the base, not the idea of a progressive tariff. Fewer than 0.1% of Swiss taxpayers were on this method in the last federal statistical snapshot the page cites. It is a niche. It is not a productised “Swiss rate” that a family office can paste into a European model.
Ordinary taxation is the default. A person who is Swiss-resident under ordinary rules declares worldwide income for federal and cantonal tax, and wealth for cantonal and communal tax. Deductions, social allowances, and the ordinary tariff apply. A family that will work in Switzerland, take Swiss nationality, or fail a cantonal forfait condition is on that track whether it likes the brochure or not. Adjacent French files such as tax residence tests in France remain a separate statute: leaving France is not the same as entering Swiss ordinary or expenditure-based taxation.
Federal law, cantonal implementation
The federal architecture sits in article 14 of the Federal Act on Direct Federal Tax (DBG) and in article 6 of the Federal Act on the Harmonisation of Direct Taxes of the Cantons and Municipalities (StHG). The consolidated acts are on Fedlex, the federal law platform. Direct federal tax has no wealth tax. Cantons levy wealth tax. That is why a forfait conversation that only quotes a federal income base is incomplete. The canton still has to say how expenditure translates into a wealth-tax base, and at which communal multiplier.
The Federal Tax Administration publishes the indexed federal figures in its tables of deductions, rates, and tariffs for direct federal tax. For 2026 the FTA table lists CHF 435,000 as the amount under article 14 paragraph 3 letter a DBG. That figure is an indexed minimum assessment base for the federal expenditure method. It is not a federal tax rate, and this article does not invent one. The 2012 reform that entered into force on 1 January 2016 set the statutory minimum at CHF 400,000 and instructed the Federal Department of Finance to index it. Families who still quote “400,000 forever” are quoting the unindexed floor, not the FTA table for the year of arrival.
How the expenditure base is built
The tax is calculated on the annual cost of living of the taxpayer and dependants, in Switzerland and abroad. Federal law then imposes minimums: the indexed federal floor just mentioned; for a taxpayer with a household of their own, seven times the annual rent or rental value; for others, three times the annual pension price for board and lodging. A control calculation then provides that the tax may not be lower than the tax, at ordinary rates, on specified Swiss-source gross items: Swiss real estate, Swiss movable property, Swiss-situs movable capital including claims secured on Swiss land, Swiss-exploited royalties and similar rights, Swiss-source pensions, and income for which the taxpayer claims treaty relief from foreign tax.
Control calculation and Swiss-source income
The control calculation is why a forfait is not a blanket exemption for Swiss assets. A family that buys a Geneva building, keeps Swiss securities, or claims treaty relief on foreign dividends is feeding the control base. FTA Circular no. 44 (24 July 2018) on expenditure-based taxation for direct federal tax remains the federal administrative guide for that architecture. Cantons apply analogous logic to their own tax, with their own minimums, which the EFD page expressly says differ from canton to canton. A ruling from the canton of intended residence is the working document. A slide that quotes a single “Swiss forfait number” is not.
Not available identically everywhere
Several cantons abolished expenditure-based taxation at cantonal level in the 2000s and 2010s. Zurich, Schaffhausen, Appenzell Ausserrhoden, Basel-Stadt, and Basel-Landschaft are the usual list in federal and cantonal materials. A family that “moves to Switzerland” without naming a canton has not chosen a method. Even among cantons that still offer the regime, minimum expenditure bases, wealth-tax multiples, and ruling practice are not uniform. The 2020s tightening is cantonal as much as federal: higher floors, stricter views of what counts as gainful employment, and less patience for a principal who still runs a foreign group from a Swiss desk in substance.
Gainful employment in Switzerland ends the right. So does Swiss citizenship. Spouses who live in a legally and factually unseparated marriage must both meet the conditions. A spouse who takes a Swiss employment contract can pull the household off the method. “I only advise my own companies from home” is a substance file, not a caption. French-resident families comparing a Swiss move with staying put still have IFI and income tax in France; see the IFI 2026 taxable-wealth inventory. A forfait does not rewrite that French file until French residence has actually ended under article 4 B.
Ordinary taxation as the comparison that matters
Ordinary taxation is not the consolation prize. For a family with modest foreign income, Swiss-source salary, or a desire to work, it is the only honest track. Worldwide income, ordinary deductions, social charges, and cantonal wealth tax on worldwide net wealth (with reliefs and treaty overlays) produce a number that can be modelled. The forfait produces a number that can be modelled only after a canton agrees an expenditure base and after the control calculation is run. Families who compare a brochure forfait with a back-of-envelope ordinary tax, without Swiss-source items and without wealth tax, are comparing two fictions.
Ordinary tax also keeps the person inside the ordinary treaty profile. Some Swiss treaties restrict benefits for persons taxed on a lump-sum basis, or require the control calculation to include treaty-relieved income. That is one reason the federal statute folds treaty-relieved items into the control base. A family that needs treaty relief on a large foreign dividend stream may find that the control calculation closes much of the gap the brochure advertised. That is a feature of the law, not a drafting accident.
The 2020s file is also a substance file. Cantonal administrations have grown less willing to treat a silent foreign chairmanship as “no gainful employment in Switzerland” when decisions, staff, and a diary sit in the commune. Federal individual-taxation reform, discussed in Swiss official materials as a coming change to how spouses are assessed, is not a new forfait tariff and this article does not invent one. It is a reminder that the ordinary track will keep moving even if the expenditure method stays on the books. A family that models only the 2016 federal floor, and ignores cantonal wealth tax, communal multipliers, and the control calculation, has not modelled Switzerland.
What a move file actually contains
A serious file names the canton, the commune, the housing arrangement (rent or owned, and the rental value), the household composition, whether anyone will work, whether anyone will naturalise, the map of Swiss-source assets and of treaty claims, and the French (or other) exit and residence analysis. It includes the FTA page, the DBG and StHG articles, the cantonal statute, and a draft ruling request. It does not include a “2026 federal rate” invented to make a European comparison table look complete.
Vellum Finance does not sell Swiss rulings. The Vellum Finance services model is fee-only coordination: residence facts on both sides of the border, the chart of companies, and a single list of questions for Swiss counsel and the cantonal administration. The 2026 question is still the one the EFD page poses. Is the family eligible. Which canton. What expenditure. What control calculation. What ordinary alternative. Until those answers exist on paper, “we will go forfait” is a preference, not a plan.
Conclusion
Swiss forfait versus ordinary taxation is a federal method implemented canton by canton. Expenditure-based taxation is available only to eligible foreign nationals who do not work in Switzerland, and only where the canton still offers it. The FTA publishes an indexed federal minimum base (CHF 435,000 in the 2026 table), not a federal rate. Seven times rent, three times pension, and the control calculation on Swiss-source and treaty-relieved items complete the federal floor. Ordinary taxation remains the comparison that has to be modelled with wealth tax included. Read admin.ch and the FTA tables, name the canton, and let a ruling, not a slogan, carry the file.
Discretion. Stability. Prosperity.
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