Lump‑sum taxation replaces a progressive income‑tax system with a single, fixed annual payment, regardless of how much you earn. It is offered by a handful of jurisdictions and is aimed at high‑net‑worth individuals whose worldwide earnings would otherwise be taxed at high marginal rates. Below is a concise overview of the four programs that currently exist, their costs, eligibility criteria, and the main advantages and drawbacks of each.
How lump‑sum taxation works
- Fixed annual payment – Instead of paying a percentage of income, residents remit a predetermined amount each year.
- Scope of income – The payment usually applies to foreign‑sourced income; income earned locally is still subject to the ordinary tax regime.
- Duration – Most schemes last for up to 15 years, after which the resident may revert to the standard tax system.
- Risk – Programs can be altered or abolished by the host government at any time.
Switzerland – “Forfait fiscal”
Switzerland’s system is the most complex of the four. Rather than a single flat fee, the tax base is derived from the higher of three measures:
- Seven times annual rent (if you lease a property).
- Three times housing costs for temporary accommodation.
- Federal minimum of 434,700 CHF (≈ $560 k).
Standard cantonal and federal rates are then applied to that base. In practice the minimum annual tax bill ranges from 250,000 CHF to 1 million CHF, depending on the canton of residence.
Key points
| Aspect | Details |
|---|---|
| Eligibility | • Foreign citizenship • First‑time Swiss residence or return after ≥ 10 years abroad • No employment or business activity in Switzerland |
| Canton distribution (2025) | Geneva ≈ 25 % of lump‑sum residents, followed by Valet 12 %, Tino 11 %, Valdon 9 % (lowest entry point ~250 k CHF). Zurich and Basil have discontinued the program. |
| Current holders | 496 non‑EU nationals (as of March 2025), a 22 % increase YoY. Largest groups: Russians 20 %, Chinese 10 %, British 10 %, Americans 8 %. |
| Investment requirement | None, but the high annual fee places the program in the ultra‑high‑net‑worth segment. |
| Benefits | Swiss political stability, high‑quality infrastructure, and a lifestyle that attracts wealthy expatriates. |
Italy – Flat tax for foreign‑source income
Italy introduced its lump‑sum regime in 2017. The flat tax applies to all foreign‑sourced income, while Italian‑source income remains subject to the regular progressive rates (up to 43 %). The fee has risen twice:
- €100 k per year (2017‑Aug 2024)
- €200 k per year (Aug 2024‑Dec 2025)
- €300 k per year (from Jan 2026 onward)
Family members can be added for €50 k each (previously €25 k). Grandfathering provisions allow those who moved before a rate increase to keep the older, lower rate for the full 15‑year term.
Eligibility
- No Italian tax residence for at least 9 of the previous 10 years (any nationality, including returning Italians).
- Income must be primarily foreign‑sourced to benefit from the regime.
Tax scope and exemptions
- Covered income – Dividends, capital gains, interest, rental income, and pensions from abroad.
- Exemptions – No Italian wealth tax on foreign real estate, no reporting of overseas holdings, and no gift or inheritance tax on foreign assets.
Practical considerations
- The €300 k annual fee becomes attractive for individuals or families earning ≈ €1.5 million or more from foreign sources.
- Below that threshold, standard Italian taxation may be cheaper.
Greece – Non‑dom regime for investors
Greece offers a comparatively low flat tax of €100 k per year on foreign‑sourced income, payable for up to 15 years. Family members can be added for an additional €20 k per adult per year. The regime also provides exemption from Greek inheritance and gift taxes on foreign assets.
Investment requirement
- Minimum €500 k investment in Greek assets (real estate, businesses, securities, or shares of Greek companies).
Eligibility
- No Greek tax residence for 7 of the preceding 8 years.
- Must transfer tax residence from a country that has a tax treaty or administrative cooperation agreement with Greece.
Complementary options
- The Greece Golden Visa (separate from the lump‑sum tax) requires at least €400 k in residential property outside tourist zones or €800 k anywhere in the country, providing residency rights alongside the tax regime.
Target profile
- High‑income individuals who also wish to deploy capital in Greece’s real estate or business sectors.
Anguilla – High‑value resident program
Anguilla’s lump‑sum system is the most straightforward: a $75 k annual payment on worldwide income, plus a $400 k investment in Anguillan real estate. Residents must spend at least 45 days on the island each year and cannot spend more than 183 days in any other single jurisdiction, preventing dual tax residence.
Features
- No income, corporate, capital‑gains, or inheritance tax beyond the annual fee.
- Minimal physical‑presence requirement (45 days).
- Suited to highly mobile individuals who prefer flexibility over a fixed location.
Comparative snapshot
| Country | Annual fee (new applicants) | Investment required | Minimum annual tax (typical) | Typical target |
|---|---|---|---|---|
| Switzerland | 250 k CHF – 1 M CHF (based on canton) | None | 250 k CHF | Ultra‑high‑net‑worth passive earners seeking Swiss lifestyle |
| Italy | €300 k (post‑2026) | None | €300 k | Families with ≥ €1.5 M foreign income, valuing wealth‑tax exemptions |
| Greece | €100 k | €500 k in Greek assets | €100 k | Investors willing to lock capital in Greece |
| Anguilla | $75 k | $400 k in Anguillan real estate | $75 k | Mobile high‑net‑worth individuals needing minimal presence |
Decision criteria
- Net‑worth and cash flow – Higher annual fees (Switzerland, Italy) suit those with substantial passive income.
- Willingness to invest – Greece and Anguilla require sizable capital commitments; assess whether the investment aligns with broader portfolio goals.
- Lifestyle preferences – Swiss cantonal location, Italian family‑friendly environment, Greek Mediterranean setting, or Anguilla’s island flexibility may influence choice.
- Regulatory stability – Programs can be altered; recent examples include Swiss cantons abolishing the regime and Italy raising its flat tax twice within two years.
Bottom line: Lump‑sum taxation offers a predictable tax outlay for high‑income expatriates, but the choice hinges on the balance between annual cost, required investment, residency obligations, and the non‑tax benefits each jurisdiction provides. Careful analysis of personal financial circumstances and consultation with qualified tax and immigration advisors are essential before committing to any program.
