The reasons capital has flowed into Switzerland for decades are not promotional: the stability of the franc, neutrality, predictable rule of law, direct democracy, a mature private-banking infrastructure with deep KYC standards. These qualities do not offer an emotional pitch — they offer infrastructural reliability that is difficult to reproduce in other jurisdictions.
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Switzerland
Switzerland in EMET's practice is, first and foremost, the place where the capital lives. The overwhelming majority of the firm's clients' liquid wealth sits in portfolios with Swiss private banks: an infrastructure built up over decades, which remains the central element of the international asset architecture even when the client lives in Italy, Cyprus, Spain, Greece or Montenegro. Swiss residency is a separate, much rarer case.
EMET handles two sides of a client's Swiss profile. First, coordination with Swiss private banks for every client regardless of where they live: KYC and source-of-funds coherence, responses to compliance enquiries, maintaining a single position across all of the client's banks. Second, support for the rare relocation cases: typically into Zug, Schwyz, Geneva or Vaud under Pauschalbesteuerung (the lump-sum tax regime) or the ordinary cantonal regime, depending on the client's profile.
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How clients use Switzerland
EMET works with several recurring scenarios on Swiss client positions.
Switzerland as the place where the capital lives, without Swiss residency. The most common scenario in EMET's practice. The client lives in Italy, Cyprus, Spain, Greece or Montenegro — while the principal investment portfolio sits with a Swiss private bank. EMET runs the banking side in coordination with the client's tax position in the country of residence: KYC coherence, responses to compliance enquiries, maintaining a single source-of-funds logic across all of the client's banks.
Capital relocation from Russia into Swiss private banks. A scenario in which the client reorganises the banking infrastructure, moving part of the capital from the Russian banking system into international banking infrastructure — typically into Swiss private banks. EMET runs the principal work: source-of-funds documentation, KYC for the receiving Swiss side, Russian-side currency control, coherence of position. Swiss banks in most cases require Russian-speaking clients to hold EU-country residence — without it, opening new accounts today is materially more difficult.
Swiss residency through Pauschalbesteuerung. A narrow but real scenario. A client with dual (European) citizenship or existing EU residence relocates to one of the HNWI-relevant cantons — typically Zug, Schwyz, Geneva or Vaud — and elects the lump-sum regime. Pauschalbesteuerung is available to foreigners not working in Switzerland and relocating to Switzerland for the first time or after a long absence.
Ordinary Swiss residency. For clients who do not qualify for Pauschalbesteuerung (e.g., conducting professional activity in Switzerland) or who consciously elect the ordinary regime. Worldwide income is taxed under the federal + cantonal + municipal scale. Cantonal variability is material: Zug or Schwyz as low-tax cantons can deliver a materially lower effective burden than Geneva or Vaud.
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Swiss banking infrastructure
Banking is the central element of a Swiss profile for most EMET clients.
Swiss private banks offer several layers of service that together comprise what is typically called «private banking»: discretionary portfolio management, advisory mandates, custody with a deep operational infrastructure, lombard lending against the portfolio, structured products, access to private equity and hedge-fund strategies through partnership structures. For a typical Russian-speaking HNWI client of EMET, a portfolio with one of the major Swiss private banks is not «one of the accounts» — it is the principal financial infrastructure of the international portion of the assets.
Modern Switzerland is not a jurisdiction of tax invisibility. It is a jurisdiction of banking stability, documentation and predictable compliance. The archaic perception of a Swiss bank as a confidentiality instrument belongs to an era closed by the introduction of CRS (see below) and the tightening of financial-crime regulation. The modern Swiss banking position works differently — through transparent KYC documentation, consistent tax logic and cross-jurisdiction coordination.
Compliance reality after 2022. Swiss banks materially raised requirements for Russian-speaking clients after the sanctions packages and the general tightening of financial-crime regulation. Opening new accounts for individuals with Russian citizenship alone has become materially more difficult; in most cases EU residency, a transparent source-of-funds history, and a consistent KYC logic across all of the client's banks are required. EMET acts as the coordination centre that ensures coherence of the position across all of the client's banking relationships — Swiss, banks in the country of residence, remaining Russian accounts and assets.
KYC and source-of-funds coherence. A central part of EMET's work. Swiss, Italian, Cypriot, Greek banks can ask the same question — but at different times and in different wording. Without a single prepared position, the client ends up answering each bank separately, and the answers begin to diverge. EMET prepares a single source-of-funds package, a single residency-and-income logic, a single documentation trail — the client presents one coherent profile to every bank in their international structure.
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Pauschalbesteuerung — the lump-sum tax regime
Pauschalbesteuerung (the lump-sum regime, also known as «forfait fiscal» in the French-speaking part) is a Swiss preferential regime for foreign residents who do not work in Switzerland and are relocating to Switzerland for the first time or after a long absence. Long established, in the form of a federal + cantonal institution, with practical application predominantly in low-tax cantons.
Several cantons have abolished the regime at cantonal level — Zürich, Basel-Stadt, Basel-Landschaft, Schaffhausen, Appenzell Ausserrhoden. The federal regime remains in place, but in practice these cantons are usually not workable choices for lump-sum taxation.
Structure of the regime. Tax is calculated not on the client's worldwide income, but on a dépense base — a computed estimate of the resident's living expenses. The federal base is subject to an absolute federal minimum and is generally at least seven times the annual rent or imputed-rental value of the housing; cantons may impose additional minimums.
Entry conditions. The individual must not be a Swiss citizen; must not work in Switzerland; must be relocating to Switzerland for the first time or after a long absence. The application is filed upon registration of tax residency in the canton; the regime is typically agreed in coordination with the cantonal tax authority.
Economics of the regime. The effective cost of Pauschalbesteuerung for HNWI families runs into hundreds of thousands of francs per year and depends materially on the canton, the housing value and the agreed expense base. For the highest-end configurations in high-demand cantons a level of CHF 400-600k+ can be realistic. For an ultra-HNWI with multi-million worldwide income this level can prove lower than ordinary worldwide-income taxation, but the actual outcome is highly canton-, family- and asset-specific. For lower income levels the ordinary regime is usually more efficient.
Coordination with other sides. Pauschalbesteuerung covers the Swiss side. Russian CFC obligations (where the client retains Russian CFC status), reporting in other jurisdictions of presence, and coordination with Swiss banks are parallel layers that EMET handles in coordination with the cantonal filing.
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Cantonal variability — Zug, Schwyz, Geneva, Vaud
Swiss taxation operates at three levels: federal (uniform across the country), cantonal (significant variation), and municipal (further variation within a single canton). The cantonal level is the principal driver of variability in effective burden.
HNWI-relevant cantons: Zug and Schwyz as low-tax options; Geneva and Vaud as private-banking and French-speaking centres where Pauschalbesteuerung remains available.
Zug — the most popular canton for Russian-speaking HNWI: low cantonal rates on income and wealth, a developed private-banking infrastructure, proximity to Zürich, the Crypto Valley ecosystem for technology entrepreneurs, Pauschalbesteuerung availability.
Schwyz — a neighbouring canton with a similar low-rate profile; less international infrastructure than Zug, but attractive to clients seeking a quieter jurisdiction.
Geneva and Vaud — traditional destinations for French-speaking and international clients. Cantonal rates are higher than in Zug/Schwyz, but the private-banking infrastructure is among the most concentrated in the world (UBP, Pictet, Lombard Odier, Edmond de Rothschild, Mirabaud have central offices in Geneva). Pauschalbesteuerung is available in both cantons.
Effective burden. Under the ordinary regime, Zug and Schwyz usually produce a materially lower effective burden than Geneva or Vaud; the actual percentage depends on income mix, wealth, municipality and deductions. Under Pauschalbesteuerung the burden is determined not by a percentage, but by the agreed dépense base.
Wealth tax. This is the part of the Swiss tax picture that clients comparing cantons only by income tax routinely underestimate. In Switzerland not only the yield on capital matters but the existence of significant wealth itself: a large liquid portfolio can materially change the family's overall burden. EMET therefore compares cantons not on a single rate but on the full picture: income tax, wealth tax, the chosen regime and the structure of the client's assets. The mechanics are set out in the note alongside.
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Coordination: Russia, EU residency, the Swiss banking side
A Swiss client position rarely works in isolation — it intersects with other elements of the international structure.
The Russian side. EMET runs the Russian side for clients who retain Russian tax residency or sit in transitional years between statuses: foreign-account disclosures (including Swiss), CFC reporting where the client controls foreign structures, currency-control filings, preparation of responses to Russian tax-authority enquiries. A Swiss account held by a Russian resident is a standard subject of Russian reporting.
European residency profile and the Swiss bank. For a Russian-speaking client, the Swiss bank today rarely looks at the client in isolation from their residency position. The bank looks not only at the capital but at where the client lives, where they pay taxes, how source of funds is substantiated and how explicable the overall structure is from a sanctions and banking-compliance perspective. This is why the planning sequence often runs in a particular order: EMET first establishes a clear European residency profile for the client, and only then discusses the Swiss banking element. If such a profile is absent, the scenario is reviewed before approaching a bank — not after a refusal.
Russia-Switzerland bilateral treaty. The 1995 double-taxation treaty (with protocols) formally governs the basic mechanisms on dividends, interest, and capital gains. After Russian Presidential Decree No. 585 of August 2023 a number of provisions were suspended on the Russian side; Switzerland has not formally suspended the treaty on its side, although separate Swiss measures since 2022 affect operational application in practice. The concrete application requires analysis on each specific transaction — which provisions are affected, which bilateral mechanisms continue to operate.
CRS / AEOI — automatic exchange of tax information. For an EMET client with a Swiss account, the central conclusion on CRS / AEOI is not the fact of automatic exchange itself but the need for the banking and tax pictures to match. What the bank collects and transmits on the account has to match what the client shows in their tax position. Any divergence — in residency, account holder, income, balances or ownership structure — stops being a theoretical risk and may become a concrete enquiry from the bank, the tax authority, or both at once.
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Typical client configurations
EMET in Switzerland works with variations of several typical configurations.
Configuration A — Banking-only client with EU residency
The client lives in Italy, Cyprus, Spain or Greece; the portfolio sits with a Swiss private bank. EMET runs the Swiss banking coordination and combines it with the client's tax position in the country of residence. Swiss residency is not established.
Configuration B — Capital relocation from Russia
The client reorganises the banking infrastructure, moving part of the capital into a Swiss private bank. EMET documents the source of funds, coordinates KYC for the receiving Swiss side, runs the Russian side on currency control. EU residency is the usual prerequisite.
Configuration C — Swiss residency in Zug under Pauschalbesteuerung
A client with dual citizenship or existing EU status relocates to Zug and activates Pauschalbesteuerung. EMET coordinates the cantonal filing, the coordination with Swiss banks (now with Swiss residency the banking compliance becomes substantially simpler), and the Russian side on CFC obligations.
Configuration D — Ordinary Swiss residency in a low-tax canton
A client who does not qualify for Pauschalbesteuerung (e.g., due to professional activity in Switzerland) selects Zug or Schwyz under the ordinary regime. EMET runs the annual tax filing at federal + cantonal + municipal levels, coordinates with the banks, runs the Russian side.
Configuration E — Multi-jurisdictional family structure with a Swiss private bank at the centre
One family member is resident in one EU jurisdiction, another in another; the children study in Switzerland or the EU. The family's capital sits with a Swiss private bank, with accounts held under different legal entities. EMET runs the coordination between all sides — tax, banking, inheritance.
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How EMET works with clients on the Swiss connection
EMET runs the strategic and coordination side of work on the Swiss element of a client's position.
Banking coordination — the principal role. For most EMET clients, the Swiss profile is the banking infrastructure. EMET prepares responses to compliance queries from Swiss private banks, ensures KYC coherence across all of the client's banks, coordinates the source-of-funds position between the Swiss layer and the EU-residency side. This is a central piece of work that runs throughout the year — banking enquiries arise routinely after a change of residency, the sale of an asset, an inheritance event.
Residency support — selective. For the rare relocation cases into Switzerland, EMET handles: the Pauschalbesteuerung application (or registration under the ordinary regime), coordination with the cantonal tax authority, annual returns (federal + cantonal + municipal), coordination of the Swiss position with the other sides of the client's structure. For specific corporate matters (where the client holds a Swiss operating company) a local treuhänder or fiduciary partner is engaged — but for the majority of client tasks EMET handles the work directly.
This is an engagement format close to a multi-family office: the annual return is only one element of the ongoing work on the client's position. The principal value is regular coordination of the position throughout the year.
The standard engagement cycle on the Swiss element runs through four phases.
1. Structural positioning
Review of the existing or planned Swiss element: the client's banking infrastructure, whether Swiss residency is needed (or not), configuration with the country of principal residence. Regime decision (Pauschalbesteuerung vs ordinary) and canton selection where relocation is in scope.
2. Banking onboarding or maintenance
For new banking relationships — KYC package preparation, support through the account-opening process, coordination with the receiving bank. For existing relationships — maintaining coherence through regular compliance events. Coordination with the client's EU-residency side where relevant.
3. KYC and source-of-funds coherence
A single source-of-funds logic across all of the client's banks — Swiss, EU-side banks, remaining Russian accounts and assets. Preparation for compliance queries as a coordinated position rather than scattered responses. This is a central part of the firm's work.
4. Residency support (for clients with Swiss residency)
Annual federal + cantonal returns, coordination with the cantonal tax authority, Russian CFC reporting for Russian residents holding structures. On a 5-10+ year horizon — discussion of long-horizon plans (continuing Swiss residency, transition to permanent residence permit, naturalisation over several decades).
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Note on applicability
The mechanisms above are a framing picture. The concrete tax outcome in any given situation depends on the owner's residency status, the regime selected (Pauschalbesteuerung or ordinary), the canton of residence, the form of asset ownership, the applicable double-taxation treaty in its current state, the residency history, and the character of the income. The same position in one canton may be taxed materially differently in a neighbouring one. Determining the actual regime calls for individual analysis against the specific structure and factual history.
Topics
If your position involves Swiss banking infrastructure or consideration of Switzerland as a place of residence (in one of the low-tax cantons under Pauschalbesteuerung or the ordinary regime) — a short conversation can help work through the role of the Swiss side in the overall structure, the choice of regime and canton, and coordination with the other sides of your international position.
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