Taxation based on expenditure, commonly called lump-sum taxation in English (forfait fiscal in French), is a method of taxation set out in federal law and applied by the cantons, Geneva among them. This page describes what the official texts say: who may apply, how the minimum tax base is set, what the control calculation is and which amounts Geneva publishes. It does not say who the regime suits and does not estimate anyone's tax: it is a table of rules, not tax advice. Each rule is followed by the article checked in the official text (texts consulted as of 17 October 2026).
Wealth management is an activity distinct from tax status. A wealth manager manages assets under a mandate; the manager does not decide a client's tax regime (see the dedicated section below).
A note on the abbreviations, which come from the French-language texts: LIFD is the Federal Act on Direct Federal Tax (DBG in German); LHID is the Federal Act on the Harmonisation of Direct Taxes of the Cantons and Communes (StHG in German); LIPP is Geneva's Personal Income Tax Act, which exists in French only; AFC is the Swiss Federal Tax Administration (FTA, ESTV in German).
What is the legal basis for lump-sum taxation?
The regime rests on three texts, read together:
- the Federal Act on Direct Federal Tax (LIFD, SR 642.11) (in French), art. 14: taxation based on expenditure for direct federal tax;
- the Federal Act on the Harmonisation of Direct Taxes of the Cantons and Communes (LHID, SR 642.14) (in French), art. 6: the framework the cantons apply to their cantonal and communal taxes;
- the Geneva Personal Income Tax Act (LIPP, RSG D 3 08) (in French), art. 14, which takes over the federal conditions and sets the Geneva minimum.
For direct federal tax, the Swiss Federal Tax Administration (AFC) published Circular No. 44, "Taxation based on expenditure for direct federal tax" (title translated from the French), dated 24 July 2018. It is listed with the other circulars on direct federal tax (in French; the English page carries only the introduction and refers to the French, German and Italian versions). On the Geneva side, the cantonal tax administration presents the regime on its page Taxation based on expenditure (in French).
Who can apply for taxation based on expenditure?
The three substantive conditions are the same in federal law and in Geneva law. Art. 14, para. 1 LIFD gives the right to be taxed on expenditure, instead of income tax, to individuals who meet all the following conditions:
- they do not hold Swiss nationality;
- they are liable to tax without limitation for the first time, or after an absence of at least ten years;
- they do not carry on a gainful activity in Switzerland.
Spouses living in the same household must both meet these conditions (art. 14, para. 2 LIFD; art. 14, para. 2 LIPP). One difference of wording is worth noting: art. 14 LIFD speaks of a "right", whereas art. 6 LHID says that "the canton may grant" that right. Federal harmonisation therefore leaves it to the cantons whether to provide the regime; Geneva has done so in art. 14 LIPP.
On its website, the Geneva tax administration sets out its practice: people with several nationalities, one of them Swiss, cannot benefit; managing private wealth is accepted "within the usual limits set by case law"; and a paid role as a director is not accepted by the canton (ge.ch, who can benefit, in French, updated 16 October 2025).
How is the minimum tax base set?
The tax that replaces income tax is calculated on the annual expenses of the taxpayer and of the persons in his or her care, in Switzerland and abroad, to maintain their standard of living. It is calculated on at least the highest of several amounts. The table below sets the texts side by side.
| Point | Federal rule (LIFD, direct federal tax) | Geneva rule (LIPP, cantonal and communal tax) | Source |
|---|---|---|---|
| Who | Persons without Swiss nationality, liable to tax without limitation for the first time or after at least 10 years' absence, with no gainful activity in Switzerland | Same conditions | art. 14, para. 1 LIFD; art. 6, para. 1 LHID; art. 14, para. 1 LIPP |
| Spouses | Both must meet the conditions | Both must meet the conditions | art. 14, para. 2 LIFD; art. 14, para. 2 LIPP |
| Minimum in francs | CHF 435,000 a year (as of 1 January 2026) | CHF 400,000 in the text of the act, adjusted each year for inflation | art. 14, para. 3, let. a and para. 6 LIFD; art. 14, para. 3, let. a and art. 67, para. 2 LIPP |
| Multiple of housing costs (head of household) | Seven times the annual rent or rental value | Seven times the annual rent or rental value | art. 14, para. 3, let. b LIFD; art. 14, para. 3, let. b LIPP |
| Other taxpayers | Three times the annual price of board and lodging | Three times the annual price of board and lodging | art. 14, para. 3, let. c LIFD; art. 14, para. 3, let. c LIPP |
| Wealth tax | Not provided for in art. 14 LIFD | 10 % surcharge on the amount of the expenditure | art. 14, para. 4 LIPP; art. 6, para. 5 LHID |
| Rate scale | Ordinary tax scale | Ordinary tax scale | art. 14, para. 4 LIFD; art. 14, para. 5 LIPP |
| Control calculation | Tax at least equal to that calculated on certain Swiss-source items | Same | art. 14, para. 3, let. d LIFD; art. 14, para. 6 LIPP; art. 6, para. 6 LHID |
The amount used is "the highest" of the minimums: art. 14, para. 3 LIFD and art. 14, para. 3 LIPP each set a floor, and the expenditure actually established may exceed it. At cantonal level, art. 6, para. 3, let. a LHID leaves each canton to set the amount in francs, and art. 6, para. 5 LHID leaves it to decide how wealth tax is covered. Geneva chose the 10 % surcharge (art. 14, para. 4 LIPP).
The amounts in francs are indexed: those in the table above may change every year.
Which minimum amounts does Geneva publish?
Art. 14, para. 6 LIFD instructs the Federal Department of Finance to adjust the federal amount each year to the Swiss consumer price index; art. 67, para. 2 LIPP instructs the Geneva Council of State to adjust the cantonal amount each year. The Geneva tax administration publishes both series on its page on indexation of lump-sum taxation agreements (in French).
| Tax period | ICC minimum (art. 14 and 67 LIPP) | ICC with 10 % surcharge | IFD minimum (art. 14 LIFD) |
|---|---|---|---|
| 2026 | CHF 426,357 | CHF 468,993 | CHF 435,000 |
| 2025 | CHF 425,194 | CHF 467,713 | CHF 434,700 |
| 2024 | CHF 421,318 | CHF 463,450 | CHF 429,100 |
Source: ge.ch, indexation page (ICC = cantonal and communal tax; IFD = direct federal tax). The federal amount of CHF 435,000 for 2026 also appears in art. 14, para. 3, let. a LIFD (as of 1 January 2026, adjustment based on the FDF ordinance of 10 September 2025, RO 2025 579). These amounts are revised every year: the ge.ch page and the text of the LIFD at the date of assessment prevail.
What is the control calculation?
The control calculation (or control tax) is an additional floor. Under art. 14, para. 3, let. d LIFD and art. 14, para. 6 LIPP, tax based on expenditure cannot be lower than the sum of the income tax and, at cantonal level, the wealth tax, calculated at the ordinary rates on all the following gross items:
- real estate in Switzerland and the income it yields;
- movable property in Switzerland and the income from it;
- movable capital invested in Switzerland, including claims secured by mortgage, and the income from it;
- copyrights, patents and similar rights exploited in Switzerland, and the income from them;
- pensions, annuities and retirement benefits from Swiss sources;
- income for which the taxpayer claims partial or full relief from foreign taxes under a double taxation agreement.
Art. 14, para. 5 LIFD and art. 14, para. 7 LIPP add a rule for income from a foreign state that is exempt on condition that Switzerland taxes it: the tax is then also calculated on the items of income of the source state that the agreement allocates to Switzerland. The Geneva administration describes the same mechanism on its page on the calculation linked to taxation based on expenditure (in French): three comparative standards, and the base that gives the highest tax is used.
What changed with the reform in force since 1 January 2016?
The federal act of 28 September 2012 revised art. 14 LIFD and art. 6 LHID. The text of the LIFD states that the new version of art. 14 has been in force since 1 January 2016 (note to art. 14 LIFD). Geneva amended the LIPP accordingly (amendment of 15 October 2015, art. 14 LIPP) and has applied the 10 % surcharge for wealth tax since 1 January 2016 (ge.ch, in French).
The transitional provisions provide that people already taxed on expenditure when the reform came into force remain subject to the former art. 14 for five years (art. 205d LIFD; art. 78e LHID). In Geneva, art. 72, para. 11 LIPP applies the former wording of art. 14 until tax year 2020 for people taxed on expenditure on 1 January 2016.
How does the regime work in practice in Geneva?
According to the cantonal tax administration, the arrangement is the subject of an agreement between the administration and the taxpayer, generally valid for five years, a period that may be shortened depending on the circumstances. The application is sent to the administration in writing with, among other things, a letter on the taxpayer's situation, a proposed amount, the lease or the rental value form and the administration's own form (ge.ch, how to benefit, in French, updated 13 June 2025). The taxpayer reports any change of circumstances without delay (marriage, acquisition of real estate, change of rent).
How does this relate to a wealth manager or family office?
Tax status and the management of assets are two separate subjects. An authorised wealth manager manages investments under a mandate; the manager's FINMA licence, information duties and supervision do not cover the taxation of clients. The manager does not decide the tax regime, does not negotiate it with the administration and does not replace the assessment. Tax questions are for the tax administration and tax advisers.
To browse Geneva wealth management providers, see the page on wealth management in Geneva; for structures that organise and monitor family wealth, the page on family offices in Geneva. For the criteria used to check a provider, see the guide on choosing a wealth manager. For the pension arrangements of people settled in Switzerland, see pensions for expats.
Our database lists 549 Geneva institutions, of which 77 are family offices (FINMA list and commercial register, registered office in Geneva, as of 17 October 2026; details on the Geneva data page). These figures describe the supply of providers; they say nothing about the tax regime of their clients.
What can be checked before signing?
Before signing a wealth management or family office mandate, the checkpoints are those of any mandate:
- The licence: is the institution in the FINMA list, with the same name and the same UID number as in the contract?
- The supervisory organisation: named in the list, named in the contract, present on the organisation's website.
- The custodian bank: account in the client's name, powers limited to what the mandate provides.
- Fees in writing: tariff, basis of calculation, bank and product charges, before signing.
- Retrocessions and third-party payments: prior written information, in line with art. 26 FinSA.
- Tax questions: these are settled by the tax administration or a tax adviser, not by the wealth manager. The lump-sum taxation agreement is concluded with the cantonal tax administration.
The directory remains a research tool: it does not assess the quality of a firm and does not replace tax or legal advice.