Starting Position
The Mertens family (anonymised) represents the new generation of German tech entrepreneurs. The founder (52) successfully sold his Berlin-based SaaS scale-up to a US strategic buyer in Q2 2025 — net proceeds of CHF 180M post-tax. The family had lived for 22 years in Berlin-Mitte/Charlottenburg, with both children (16, 19) in the international school and university system respectively.
Trigger for engaging Beherzig: the Berlin Senate exodus wave 2026 combined with the announced German inheritance-tax reform (planned for Q4 2026). The Mertens were seeking:
- Lump-sum taxation in the Canton of Zug for post-exit wealth without full German tax exposure
- A representative family villa as a Swiss anchor — Risch-Rotkreuz or Walchwil
- A Liechtenstein foundation for multi-generational security (immune to inheritance tax)
- A NextGen sub-allocation pathway for the two children (16, 19) with an ETH/HSG education track
Beherzig Solution: 4-Phase Mandate
Phase 1: Pre-Migration Berlin (Months 1-2)
- Preliminary lump-sum taxation opinion for the Canton of Zug with PwC Zug (tax base CHF 600,000)
- German exit-tax analysis under §6 AStG with Flick Gocke Schaumburg (Berlin tax firm) — preparation of the deferral application
- Liechtenstein foundation preparation (Industrie- und Finanzkontor, Vaduz)
- Beherzig off-market search profile: Risch-Rotkreuz / Walchwil, ≥CHF 15M, lake-view plateau, heritage villa with parkland plot ≥3,500 m²
Phase 2: Property Sourcing Zug (Months 2-4)
- Beherzig Confidential Pool: 5 NDA-protected candidates in Risch/Walchwil/Oberwil identified
- 3 private viewings with founder + spouse (one inspected during a late-Q4 2025 snowfall)
- Preference for a Risch-Rotkreuz plateau villa (built 1998, 720 m² living space, 4,200 m² plot, Lake Zug view)
- Off-market negotiation via the seller's lawyer (pharmaceutical heir, older family)
- Final price: CHF 18M (BOMPI +14% vs. the public Risch plateau level in Q1 2026)
Phase 3: Closing + Foundation Setup (Months 4-6)
- Liechtenstein foundation established (foundation board: 2 Industrie- und Finanzkontor lawyers + Mertens founder)
- Villa acquisition directly by the foundation (Lex Koller permit ZG granted to the foundation)
- Lump-sum taxation ruling for the Canton of Zug signed (CHF 600,000 tax base)
- German exit-tax deferral under §6 AStG approved (10-year plan, against security)
- The Mertens family officially relocates to Risch-Rotkreuz (Q1 2026)
Phase 4: Family Office Transition + NextGen (Months 6-8)
- Single-family office Mertens AG established in Zug (3 employees, headed by a CIO ex-UBS)
- NextGen sub-allocation: CHF 6M per child in an education trust (locked until age 25)
- Elder son (19) studying computer science at ETH, daughter (16) at International School Zug
- Charitable Mertens Education Foundation (CHF 3M seed, focus on DACH tech education)
Outcome 12 Months Post-Closing (Q2 2026)
Tax Optimisation
- Germany pre-relocation: ~CHF 4.2M income tax + capital-gains tax annually (on asset returns)
- Switzerland forfait Zug post-2026: ~CHF 240,000/year (tax base CHF 600,000 × 40% federal/cantonal/municipal)
- Saving: ~CHF 3.96M annually (-75% compared with pre-migration)
- Inheritance-tax effect: The Liechtenstein foundation fully neutralises the German inheritance-tax reform risk
Family Office Build-Up
- Single-family office Mertens AG operates in Zug from the Risch-Rotkreuz villa annex (3 FTE, multi-asset mandate)
- NextGen education trusts lock both children until age 25, followed by a mentoring pathway with the father
- Beherzig conducts quarterly reviews with the foundation board + CIO + NextGen
Lifestyle + Heritage
- The Risch-Rotkreuz villa becomes the family anchor — Alpine panorama across the Rigi/Pilatus, 25 min. from Zurich Airport
- The Mertens Education Foundation funds 4 annual ETH STEM scholarships for DACH students
- The elder son commutes from Risch to Zurich ETH (direct S-Bahn link, 35 min.), the daughter attends ISZL Zug
Key Learnings for Post-Exit Founder Clientele
1. The Berlin Senate exodus wave is real. Tech founders with exit volumes ≥CHF 50M are increasingly relocating — Switzerland (Zug, Zurich), Portugal NHR, Dubai. Beherzig recommends Switzerland for families with DACH roots — cultural proximity + schooling continuity.
2. §6 AStG exit-tax deferral is decisive. German exit tax can be deferred over 10 years — against security. Without deferral, the Mertens migration would have been financially unattractive. Early tax planning 6+ months before departure is mandatory.
3. A Liechtenstein foundation neutralises the inheritance-tax reform risk. The German inheritance-tax reform announced for Q4 2026 would hit families with ≥CHF 100M severely. A Liechtenstein foundation (recognised in CH/DE/FL) offers full protection — when correctly structured.
4. A single-family office in Zug is a location advantage. Zug offers lump-sum taxation, a Crypto Valley ecosystem, ETH connectivity and multinational service providers. For tech founders, it is an ideal family-office home with access to the German talent network.