Starting Position
In this scenario, the fictitious Hartmann-Walker family is a German-British family in its second generation. The father (58) has been a partner in the London private-equity business of an international fund for many years; part of the family's wealth consists of carried-interest entitlements, part sits in a small family office (real estate, equities, fund holdings). The four adult children (24–32) live and work in London, New York and Cambridge.
In this scenario, the considerations are triggered by the abolition of the UK non-dom regime and changes to the taxation of carried interest in the United Kingdom. The family would like to assess:
- whether lump-sum taxation in the Canton of Grisons (St. Moritz/Pontresina) could be an option
- a historic chalet in the St. Moritz area as a long-term family meeting place
- a suitable wealth and succession structure (e.g. a foundation) – to be reviewed with specialists
- an energy renovation that preserves the character of the house
- how the family could settle in socially and culturally
Typical Process in This Scenario (4 Phases)
Phase 1: Preliminary clarifications before the move (months 1–3)
- Preliminary review of lump-sum taxation in the Canton of Grisons by a tax adviser (in this scenario with an assumed assessment base of CHF 850,000)
- Clarification of UK exit and carried-interest questions by a law firm in London
- Review of a possible foundation or holding structure with a trust company – including whether such a structure would be compatible with the property purchase
- Search profile: St. Moritz / Champfèr / Pontresina area, historic chalet, mountain view, suitable for renovation, price range from approx. CHF 28M (illustrative)
Phase 2: Property search in the Engadine (months 3–6)
- Search for suitable properties, including beyond public listings, through discreet enquiries with owners and local contacts
- Viewings with the couple, ideally in both winter and summer
- In this scenario: the favourite would be an early-20th-century chalet with around 1,000–1,200 m² of living space and generous grounds (fictitious property)
- Discreet negotiation with a vendor family that has owned the house for generations
- Purchase price in this scenario: illustrative range CHF 28–35M, depending on condition, location and market conditions
Phase 3: Purchase, structure and move (months 6–9)
- Any foundation or holding solution would be worked out with specialists; its design and tax effect would need to be reviewed individually
- Lex Koller questions (buyer, residence status, purchase via a structure) would need to be clarified in advance with the competent authority – a purchase via a foreign foundation is delicate from a permit perspective
- Lump-sum taxation would need to be clarified in advance with the cantonal tax office (advance ruling)
- The tax treatment of carried interest on departure would need to be assessed by specialists in both countries
- In this scenario, the family could move to St. Moritz once these questions are resolved
Phase 4: Renovation and settling in (months 9–12)
- Energy renovation (e.g. towards the Minergie standard): illustrative budget CHF 4–6M, coordinated with heritage conservation and municipal building rules
- Possible measures: better insulation, heat recovery, geothermal probe (if permitted), restoration of the larch façade
- Contacts with local clubs and cultural and sports institutions in the Engadine
- A regular family council to involve the next generation early on
Possible Outcome in the Scenario (Illustrative)
Tax Considerations (Simplified Model Calculation)
- Under lump-sum taxation, tax is based on living expenses rather than income and wealth; in a simplified model calculation with a CHF 850,000 assessment base, the annual tax would be in the range of a few hundred thousand francs
- Whether and to what extent this would be more favourable than the UK situation depends on income, wealth, timing of the move and treaty questions
- The treatment of existing carried-interest entitlements on departure would need separate review
- Simplified model calculation, not tax or legal advice.
Renovation and Local Character
- An energy renovation could significantly reduce energy demand
- With careful planning, the larch façade, shingle roof and historic parlours could be preserved
- Geothermal probes require a permit; their suitability depends on the site
Succession and Family
- The chalet could become the family's shared meeting place in summer and winter
- Involvement in local clubs and cultural initiatives can make settling in easier
- Succession planning with clear rules for the children would need to be worked out with specialists
What the Scenario Shows
1. Timing matters. When moving away from the United Kingdom, legislative changes and cut-off dates can play a role. Tax questions should be clarified early by specialists in both countries.
2. St. Moritz can be attractive as a main residence. Quality of life, nature and a rail connection to Zurich of around three hours speak for the location; whether lump-sum taxation is possible and sensible must be assessed individually.
3. Renovation can preserve the value of a historic chalet. Energy measures should be coordinated early with heritage conservation and the municipality.
4. Settling in takes more than a house. Contacts with local clubs and institutions help a family feel connected over generations.