Starting point of the scenario
The Marchand family is an entirely invented French entrepreneurial family from the Lyon area. The entrepreneur (49) runs a mid-sized company in the luxury goods sector, her spouse (47) has a background in private banking, and their two children (15–18) attend an international school.
Starting point of the scenario: a partial sale of the family business (illustrative proceeds approx. CHF 25–30M) and the high tax burden in France (income tax and social contributions, the IFI real-estate wealth tax on French property, inheritance tax questions). The family is considering a move to Switzerland under lump-sum taxation, a second home in a ski resort and cross-border planning.
Typical process in this scenario (5 phases)
Phase 1: Tax pre-planning (Months 1–2)
- Vaud lump-sum taxation (Vevey municipality): the taxable base would need to be clarified in advance with the cantonal tax administration; the model assumes an expenditure base of CHF 950,000 per year
- Coordination with a tax adviser in France on a possible French exit tax on business shareholdings
- Review by specialists of treaty residence under lump-sum taxation (Switzerland–France double tax treaty)
- Application for a B residence permit "without gainful activity" in Vaud; processing time depends on the authority
Phase 2: Property search Vevey (Months 1–3, in parallel)
- Search for suitable apartments and villas in Pully, Vevey and Lutry, including outside public listings
- In the scenario: a lakeside apartment (approx. 180 m², 4 bedrooms, Lake Geneva view, illustrative order of magnitude CHF 4–4.5M)
- As EU nationals with actual residence in Switzerland, buying the main residence would generally not require Lex Koller authorisation – to be checked case by case
- Notarisation typically after due diligence (approx. Month 3)
Phase 3: Chalet Crans-Montana (Months 2–6, in parallel)
- Purchase before taking up residence in Switzerland: the family would count as persons abroad – a Lex Koller application in Valais and an available quota would be required
- Purchase after actually taking up residence: for EU/EFTA nationals the authorisation requirement generally falls away; the timing should therefore be clarified with specialists in advance
- Second Homes Act: in Crans-Montana, mainly properties built under the old law would be eligible
- In the scenario: a chalet from the 1990s in Plans-Mayens (approx. 240 m², panoramic setting, illustrative order of magnitude CHF 7–9M)
Phase 4: Physical move (Months 4–6)
- Move from Lyon to Vevey
- Enrolment of the children at an international school in the region
- Deregistration of the French tax domicile with complete documentation
- Start of lump-sum taxation in Vaud from the date of arrival (as decided by the authority)
Phase 5: Evidencing the centre of life (Month 6+)
- Ongoing documentation of residence in Vaud: invoices, subscriptions, local doctor, school
- Coordination with the French tax adviser, as French tax authorities tend to review moves to Switzerland closely
- First tax return under lump-sum taxation in the following year
Possible outcome in the scenario (illustrative)
Simplified model calculation (not tax or legal advice)
- France (model assumption): income tax, social contributions and IFI in the order of approx. CHF 1.5–1.8M per year
- Vaud, lump-sum taxation (model assumption): approx. CHF 250,000–320,000 per year, including wealth tax on a lump-sum basis
- Context: in this scenario the annual tax burden could fall considerably. The actual amount depends on the taxable base, the control calculation, treaty status and the French exit tax; an individual review by specialists is required.
Possible wealth structure
- Main residence Vevey (illustrative CHF 4–4.5M, direct family ownership)
- Second home Crans-Montana (illustrative CHF 7–9M, direct ownership)
- Liquid assets managed via a private bank in Geneva
- Review with the tax adviser of a restructuring of the French holding before departure
Lifestyle + education
- Vevey: apartment directly on the lake, weekly Lutry market, gastronomy of the Lavaux UNESCO region
- Crans-Montana: winter skiing, summer golf, family weekends at the chalet
- Whether the entrepreneur can keep a non-executive board seat at the French company without jeopardising the lump-sum conditions (no gainful activity in Switzerland) would need to be clarified in advance
What the scenario shows
1. Lump-sum taxation and property purchases belong in a single timeline. The timing of the chalet purchase (before or after taking up residence) helps determine whether Lex Koller authorisation is needed – and with it, timelines and uncertainty during the transition.
2. Vevey (Vaud) is a natural choice for French-speaking families. Proximity to Geneva, a French-speaking environment, international schools in the region and the option of lump-sum taxation in Vaud.
3. Leaving France needs careful documentation. An actual centre of life in Switzerland and complete documentation are key; coordination with the French tax adviser is part of it.
4. The family's everyday life is part of the proof of residence. School, local doctor, clubs and ongoing contracts locally can indicate genuine establishment in Switzerland.