LUMP SUM TAXATION IN SWITZERLAND, CANTON TICINO

Individuals with a high net wealth and important foreign source income, who want to make Switzerland, and particularly Canton Ticino, their country of residence, have the option of being
taxed with a simplified lump sum taxation system or expenditure-based system, computed only on the worldwide living expenditures (also called lump sum or global taxation).

We find the legal basis in the Cantonal Tax Law and in the Direct Federal Tax Law as well as in the new Circular no. 44 issued on 24 July 2018, which replaces the previous Circular No. 9 of
1993. The purpose of the new provisions is to clarify the application of the legislation on direct federal tax.

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