Strategic Relocation: Key Considerations for UK Entrepreneurs Moving to Switzerland

A comprehensive guide based on expert insights from Bellecapital and PwC

For UK-based entrepreneurs contemplating a move to Switzerland, the decision involves far more than simply relocating to a picturesque Alpine setting. It requires careful orchestration of tax planning, business exit strategies, and wealth management considerations. In a recent case study discussion, Matthew Barrett from Bellecapital and Lisa Cornwell from PwC outlined the critical factors that high-net-worth individuals must address when making this significant life transition.

The Perfect Storm: Why Now?

Recent changes to UK non-dom rules have sparked increased interest in Swiss relocation. As Cornwell notes, "We see a lot of people considering their options for different reasons," with Americans and Brits particularly active in exploring offshore opportunities. For entrepreneurs with substantial business holdings, the timing of this move can have profound financial implications.

Exit Planning: Getting the Timing Right

The cornerstone of successful relocation is establishing a clear, fixed exit date from the UK. "We see very often people thinking they've left and haven't actually," warns Cornwell. This "tail" of continued UK tax residence can derail even the most carefully laid plans.

For business owners, the critical question becomes: sell before or after leaving?

Switzerland's absence of capital gains tax (except on real estate) presents a compelling opportunity to defer business sales until after establishing Swiss residency. However, this requires absolute certainty about your exit date and careful management of where business activities are conducted during the transition period.

The Day Count Dilemma

Many relocating individuals underestimate the importance of precise record-keeping. Switzerland and the UK apply different residency rules—Switzerland counts presence during any part of a day, while the UK requires presence at midnight. Simple calendar tracking or Excel spreadsheets can suffice, but accuracy is paramount to avoid accidentally triggering tax obligations in either jurisdiction.

Choosing Your Swiss Home: Beyond Tax Considerations

While tax advantages may drive initial interest, successful relocation requires lifestyle alignment. "You should never move just for tax," Barrett emphasizes. "Otherwise you won't stay where you've moved to maybe long enough to settle in."

The selection process begins with non-tax considerations: language preferences (French, German, or Italian regions), proximity to international airports, and lifestyle priorities. Popular cantons for UK relocators include Zug, Schwyz, Geneva, and Valais, with mountain regions like Verbier attracting a significant British diaspora.

The Lump Sum Taxation Advantage

For those not planning to work in Switzerland, lump sum taxation offers an elegant solution. This regime allows individuals to pre-agree a tax amount with their chosen canton, simultaneously addressing immigration and tax concerns. However, eligibility requires that you haven't been a Swiss tax resident previously and won't engage in employment within Switzerland.

Trust Structures: Navigating Uncharted Waters

Switzerland has no trust law, creating unique challenges for UK entrepreneurs with existing trust structures. Swiss authorities may attribute trust income and wealth directly to the settlor if they remain involved in decisions or receive distributions.

PwC recommends proactively seeking rulings from Swiss authorities to establish certainty. Cornwell recounts cases where Swiss tax treatment diverged significantly from the settlor's expectations, highlighting the need for careful advance planning rather than assuming existing structures will remain effective.

Portfolio Reconstruction: A Blank Canvas Opportunity

Moving to Switzerland presents a remarkable opportunity for portfolio restructuring. The absence of capital gains tax enables a complete reset—selling concentrated positions, rebalancing asset allocations, and establishing new investment strategies without tax friction.

Barrett identifies currency as a major consideration. Transitioning from sterling to Swiss francs affects fixed income allocations, potentially driving higher equity exposure since Swiss franc bonds currently offer minimal yields. For business sale proceeds, pound cost averaging over 6-12 months helps smooth market volatility and avoid the pitfalls of market timing.

Succession Planning: The Relocation Window

The move to Switzerland creates a natural opportunity for difficult family conversations about wealth transfer. "A relocation is a really good time to bring it up," Cornwell suggests, "because by kind of blaming it on the fact that you're moving, it takes a bit of the heat away."

Critical questions include whether adult children want involvement in family businesses, how rental properties should be managed, and when gifts should be made. With a November 2025 referendum potentially introducing 50% tax on assets over CHF 50 million, timing considerations have become even more pressing.

The Swiss Banking Advantage

Switzerland remains the world's largest offshore booking center, managing approximately CHF 2.6 trillion in assets. This infrastructure, combined with extensive bilateral agreements and political stability, creates compelling reasons to maintain Swiss-based wealth management even if future mobility leads elsewhere.

For UK entrepreneurs, Brexit has actually strengthened Switzerland's position. "Having fiscal stability and government stability and safety is why people want to bank in Switzerland, and also why they want to live here," Barrett observes.

Final Considerations

As Cornwell concludes, successful relocation planning centers on two fundamental questions: What's happening with the business, and where will you base yourself in Switzerland? Once these anchors are established, the complex tax, trust, and investment considerations can be systematically addressed.

The key is approaching relocation as a comprehensive life decision rather than purely a tax-planning exercise—one requiring expert guidance, meticulous timing, and realistic lifestyle assessment.