Starting Position in the Scenario
In this scenario, the Whitfield family (fictitious) is a 4th-generation British business family with family wealth in the illustrative range of CHF 250–300 million. The patriarch (62) and his wife (58) have lived in London for many years. The three children (28, 31, 35) are spread across the UK, the USA and the EU — each pursuing their own career.
What triggers the considerations in this scenario: the abolition of the UK non-dom status, combined with the handover of family-office responsibility to the next generation due in a few years. The family would typically be looking at questions such as:
- Would a move to Switzerland under lump-sum taxation (Bernese Oberland) make sense and be permissible?
- How do you find a prestigious family chalet as a cross-generational anchor?
- Which foundation or trust structure, if any, would be suitable for an orderly handover?
- How can the next generation be involved in a structured way?
Typical Process in This Scenario (4 Phases)
Phase 1: Preliminary Clarifications (Months 1–3)
- Preliminary review of lump-sum taxation in the Canton of Bern (Saanen) by a specialised tax adviser
- Review of the tax consequences of leaving the UK by UK specialists
- Clarification of possible foundation or trust structures with a law firm or a fiduciary office (e.g. in Vaduz)
- Search profile: Saanen, illustrative range CHF 20–25 million, traditional chalet with mountain views and renovation potential
Phase 2: Property Search (Months 3–5)
- Search for suitable properties, including those not publicly listed
- Discreet viewings of a small shortlist with the couple
- In the scenario: the favourite would be an older chalet (e.g. built in the 1930s, around 800 m² of living space, generous plot)
- Negotiation with the vendor family, provided they wish to sell discreetly
- Price: illustrative range CHF 20–25 million; market value to be verified independently
Phase 3: Acquisition and Structuring Questions (Months 5–7)
- Decide whether a foundation makes sense at all and who would sit on its boards (professionals and family members)
- Route of acquisition: whether a purchase via a foreign foundation would be possible would need to be clarified in advance under the Lex Koller with the competent authority of the Canton of Bern; when taking up residence in Switzerland, a direct purchase as a main residence is often the more obvious route
- Lump-sum taxation: the assessment basis would need to be agreed in advance with the tax authority (in the scenario e.g. around CHF 700,000 per year)
- The tax consequences of leaving the UK would need to be settled before the move
- The couple could then move their residence to Saanen
Phase 4: Involving the Next Generation and Renovation (Months 7–9)
- Workshops to involve the next generation (children, foundation boards, advisers)
- Possible sub-portfolios per child with their own investment responsibility (in the scenario e.g. CHF 5–10 million each, illustrative)
- Energy retrofit of the chalet, e.g. to Minergie standard (illustrative range CHF 3–5 million, construction period of over a year)
- Optional: considering a charitable family foundation with a local focus
Possible Outcome in the Scenario (Illustrative)
Tax Order of Magnitude (Simplified Model Calculation)
- UK assumption: income and capital gains taxes of several million CHF per year
- Switzerland assumption (lump-sum taxation): tax based on an assessment basis of e.g. around CHF 700,000 — in the order of a few hundred thousand CHF per year
- Note: simplified model calculation, not tax or legal advice. The actual burden depends on canton, municipality, asset structure and other factors and must be reviewed individually by professionals.
Generational Handover
- A suitable structure could help preserve the chalet as a family anchor and avoid fragmentation on inheritance — depending on its design and the legal situation
- Sub-portfolios with their own responsibility could give the next generation room to shape things
- Regular family meetings with the foundation boards would be advisable
Quality of Life and Preservation
- The chalet could become the family's meeting place — for example during summer holidays and at Christmas
- A careful energy retrofit could significantly reduce heating demand without losing the character of the house (heritage-protection requirements to be clarified in advance)
- Charitable involvement in the region would be conceivable, but is not part of the property question
What the Scenario Shows
1. Changes in the home country often trigger location questions. Families with substantial wealth then typically compare several options — such as Swiss lump-sum taxation, other flat-rate regimes or remaining in their current system. The choice depends on the individual situation.
2. Foundation structures are not automatic. Whether and how a foundation is recognised in Switzerland, and what its tax consequences are, can vary greatly depending on its design; an individual review by professionals is required.
3. Discreet sales follow their own rules. In sought-after locations, some properties are not advertised publicly. Prices should nevertheless be checked independently for plausibility.
4. Involving the next generation early pays off. Discussing handovers early makes it more likely that knowledge and cohesion are preserved within the family.