Singapore VCC insights

Singapore vs Switzerland Family Office After the 2025 Swiss Inheritance Tax Vote

By VCC Editorial Team · Published 12 October 2026

Short answer: Swiss voters rejected the proposed 50% federal inheritance and gift tax on 30 November 2025, so Switzerland still has no federal estate tax. Cantonal inheritance, gift and wealth taxes remain. Singapore removed estate duty for deaths from 15 February 2008 and generally does not tax capital gains. Many families end up using both.

This article is general information only and is not legal, tax or investment advice. For matters needing legal advice, we work with a panel of experienced Singapore law firms.

For ultra-high-net-worth (UHNW) families, the Singapore vs Switzerland family office decision was reopened by the Swiss federal vote of 30 November 2025. A proposal for a 50% federal tax on large estates and gifts was put to the people and the cantons, and it was defeated. Below we set out what the vote settled, what it left untouched, and how the two centres now compare. All sources are official government, regulator or legislation websites, checked on 12 October 2026.

What did the Swiss inheritance tax vote of 30 November 2025 decide?

It rejected a new federal inheritance and gift tax. No federal estate tax exists in Switzerland today, and the vote kept it that way.

The Federal Council’s page on the initiative gives its official title: “For a social climate policy, financed fairly through taxation (Initiative for a Future)”. It proposed “a federal tax of 50% on estates and gifts, with the first CHF 50 million exempt”. Revenue was to be split two-thirds to the Confederation and one-third to the cantons, earmarked for climate measures. The Federal Council’s explanatory booklet adds:

• There were no exemptions for surviving spouses, descendants, charities or business assets.
• The tax would have applied to estates and gifts from the day the initiative was accepted. Measures against avoidance, such as leaving Switzerland, were to follow within three years.
• The Federal Tax Administration (ESTV) estimated that in 2021 about 2,500 taxpayers in Switzerland had wealth above CHF 50 million.
• The Federal Council and Parliament recommended rejection. The National Council voted 132 to 57 against, with 8 abstentions, and the Council of States voted 36 to 7 against.

The admin.ch page records that “the Swiss people rejected” the initiative. We could not read the figures on the Federal Chancellery’s results page, so we do not quote percentages.

What did the vote not change for wealthy families in Switzerland?

It left cantonal inheritance and gift taxes, cantonal and communal wealth tax, and the expenditure-based regime untouched.

Cantonal inheritance and gift tax. The ch.ch federal portal states that “all the cantons apart from Obwalden and Schwyz levy an inheritance tax” and that “normally, spouses, registered partners and their descendants (children and grandchildren) are exempt from the tax”. Unrelated heirs pay “a significantly higher amount”, so bequests outside the direct line still need planning.

Wealth tax. ESTV’s “The Swiss Tax System” (2025 edition) confirms that “the cantons and communes levy a tax on the assets of individuals”, assessed every year on net assets. The federal wealth tax on individuals was abolished in 1959. For a large liquid portfolio, this annual charge is the main structural difference from Singapore.

Expenditure-based taxation. People without Swiss citizenship who become resident for the first time, or after at least ten years away, and who do not work in Switzerland, may be taxed on their worldwide living expenses instead of their income (art. 14 of the Federal Act on Direct Federal Tax). ESTV’s 2026 guidance sets the federal minimum base as the highest of CHF 435,000, seven times the annual rent or rental value of the home, or three times the cost of board and lodging. The regime has been abolished in Zurich, Basel-Stadt, Schaffhausen and Appenzell Ausserrhoden, and Basel-Landschaft now limits it to the year of arrival. Cantons decide how far it covers wealth tax.

The vote removed a tail risk, but choosing a canton still matters as much as choosing Switzerland.

How does Singapore’s tax position compare for UHNW families?

Singapore has no estate duty for deaths on or after 15 February 2008 and generally does not tax capital gains. Income tax is progressive, with a top resident rate of 24%.

The Inland Revenue Authority of Singapore (IRAS) states that “Estate Duty has been removed for deaths on and after 15 February 2008”. On capital gains, the IRAS e-Tax Guide “Tax Treatment of Gains or Losses from the Sale of Foreign Assets (Third Edition)”, published 6 June 2025, states that “Singapore does not tax gains from the sale or disposal of assets that are capital in nature, whether they are foreign-sourced or Singapore-sourced”. Trading gains remain taxable, and under section 10L of the Income Tax Act 1947, foreign disposal gains received in Singapore by entities of a relevant group without adequate economic substance can be taxed for disposals on or after 1 January 2024. From YA 2024, chargeable income “in excess of” S$1,000,000 is taxed at 24% for resident individuals.

With no death tax to plan around, the focus shifts to substance, residence and income characterisation. Our note on whether Singapore has estate tax covers the remaining stamp duty and probate points.

Singapore vs Switzerland family office: how is each regulated?

Both keep a family-money-only office outside full licensing: Singapore through a class exemption with notification, Switzerland through how its licensing triggers are drawn.

In Singapore, the MAS revised framework for single family offices (SFOs) took effect on 15 June 2026. It is a straight-through class exemption. A qualifying SFO must be incorporated in Singapore, notify MAS within 14 days of commencing operations, keep an account with a MAS-licensed bank and file an annual return. Existing SFOs have until 15 June 2027 to comply. See our guide to the 15 June 2027 transition.

In Switzerland, the Financial Institutions Act (FinIA, SR 954.1) requires portfolio managers and trustees acting “on a commercial basis” to hold a licence from the Swiss Financial Market Supervisory Authority (FINMA) and to be supervised by a FINMA-authorised supervisory organisation. FINMA’s guidance treats activity as commercial above any of three thresholds: gross earnings over CHF 50,000 a year, more than 20 contractual partners, or more than CHF 5 million under management or in trust at any time. It adds that “certain activities linked to legal exemptions (e.g. the exclusive management of assets of family-related persons) are not to be taken into account”. In principle, a Swiss SFO serving only family members therefore sits outside FINMA licensing. There is no notification filing; the office relies on the exemption being correctly applied. In both centres, third-party money makes the business a licensable manager.

How do banking confidentiality and tax transparency compare?

Both protect banking confidentiality by statute and both exchange account information automatically, so neither offers secrecy from a home tax authority.

Singapore’s Banking Act 1970, section 47, provides that customer information “must not, in any way, be disclosed by a bank in Singapore or any of its officers to any other person except as expressly provided in this Act”. An individual who breaches it faces a fine of up to S$125,000, imprisonment for up to 3 years, or both. Switzerland’s equivalent is article 47 of the Banking Act, which the Federal Council describes in its February 2022 digital finance report as a professional secrecy rule with “severe criminal penalties”, alongside article 69 of FinIA.

Neither rule blocks the Common Reporting Standard (CRS), the Organisation for Economic Co-operation and Development (OECD) standard for automatic exchange of information (AEOI). IRAS states that CRS has applied in Singapore since 1 January 2017, with exchanges since September 2018, and that the amended CRS takes effect from 1 January 2027. The Swiss Federal Department of Finance confirms automatic exchange with partner states under the same standard, with amended Swiss legislation due in force on 1 January 2026. See our CRS 2.0 briefing.

How do residence, trusts and currency differ?

Swiss residence is decided canton by canton with federal oversight, while Singapore runs national programmes. Switzerland recognises foreign trusts but has no trust law of its own.

Residence. A national of a country outside the European Union and European Free Trade Association (EU/EFTA) who wants to live in Switzerland without working must apply to the cantonal immigration authority before arriving. The applicant must show sufficient financial resources and adequate accident and health insurance (ch.ch). The State Secretariat for Migration’s directives (as at 15 June 2026) deal separately with residence without gainful activity and residence on grounds of “important public interests”. In Singapore, the Economic Development Board’s Global Investor Programme (GIP) Option C requires a Singapore single family office with at least S$200 million in assets under management (AUM), of which at least S$50 million must be transferred into Singapore and deployed in specified investments. The Family Office Principal needs at least S$200 million of net investible assets and five years of track record (GIP factsheet, 5 May 2025). Our sister site Singapore Employment Agency covers passes and the GIP.

Trusts. The Federal Office of Justice states (in German) that Switzerland so far has no trust law of its own, and that foreign trusts have been recognised since the Hague Trust Convention entered into force for Switzerland on 1 July 2007. A Swiss trust proposal was dropped after the Federal Council found no sufficient political consensus on 15 September 2023; Parliament wrote off the motion by 27 February 2024. Trustees acting commercially in Switzerland need a FINMA licence. Singapore law recognises express trusts directly. The Ministry of Law notes that trust business is licensed by MAS under the Trust Companies Act 2005 unless exempted, and that a private trust company needs no licence but must engage a licensed trust company for certain checks; see our private trust company guide.

Currency. MAS keeps the Singapore dollar nominal effective exchange rate “within a policy band consistent with ensuring price stability”. For families with liabilities in Europe and Asia, holding CHF and SGD is a currency decision as much as a location one.

How do the two centres compare side by side?

The table summarises the verified position on 12 October 2026; unverified points are flagged rather than estimated.

Factor	Switzerland	Singapore
Legal framework	Federal, cantonal and communal tax layers; FinIA for managers and trustees	Single national system; SFO exemption in the Securities and Futures (Licensing and Conduct of Business) Regulations
Death and gift taxes	No federal tax (federal proposal rejected 30 November 2025); cantonal inheritance tax except Obwalden and Schwyz, spouses and descendants normally exempt	Estate duty removed for deaths on or after 15 February 2008
Annual wealth tax	Cantonal and communal tax on net assets	No equivalent net wealth tax found in the IRAS guidance reviewed
Capital gains	Outside the scope of the official sources checked for this article	Capital gains generally not taxed; s 10L for foreign disposals from 1 January 2024
Personal income tax	Federal maximum 11.5% plus cantonal and communal tax; expenditure-based option, 2026 federal minimum base CHF 435,000	Progressive, top resident rate 24% above S$1,000,000 from YA 2024
SFO licensing	Outside FINMA licensing in principle where only family-related assets are managed	MAS class exemption from 15 June 2026; notify within 14 days
Banking confidentiality	Banking Act art. 47; AEOI with partner states	Banking Act 1970 s 47; CRS since 1 January 2017
Residence	Cantonal permit with federal oversight; expenditure-based tax in many cantons	GIP Option C (S$200 million AUM, S$50 million deployed); work passes for staff
Trusts	No domestic trust law; foreign trusts recognised since 1 July 2007; FINMA-licensed trustees	Express trusts under Singapore law; MAS-licensed trust companies (Trust Companies Act 2005); private trust company exemption
Currency	CHF	SGD; MAS keeps the nominal effective exchange rate within a policy band
Talent and cost	Licensed portfolio managers and trustees under FinIA; tax and living costs vary by canton	13O/13U fund schemes require qualifying investment professionals and minimum local business spending; GIP Option C requires family office hires

When is the answer “both”, and how would that work?

When a family spans Europe and Asia, or wants residence in one place and investment management in another, the answer is often “book in one, manage in the other”.

A common pattern is for the principal to live in a Swiss canton under ordinary or expenditure-based taxation and keep European bank relationships there. Asian investments are managed from a Singapore SFO or a Variable Capital Company (VCC). The reverse also occurs, with Singapore-resident families booking assets with Swiss custodians for diversification. A workable sequence:

1. Map each family member’s current and future tax residence, and the cantonal inheritance rules for the expected heirs.
2. Decide where investment decisions will actually be taken, because that place determines licensing (MAS or FINMA) and tax substance, including section 10L in Singapore.
3. Choose the holding structure (foreign-law trust, private trust company, VCC or company) and confirm that it is recognised in both centres.
4. Open banking in each centre and confirm each entity’s CRS status.
5. Apply for residence once the structure and tax arrangement are clear.

For another hub comparison, see Singapore vs Dubai.

Frequently asked questions

Did Switzerland introduce a federal inheritance tax in 2025?

No. The Swiss people rejected the Initiative for a Future on 30 November 2025, so there is still no federal inheritance or gift tax.

Do Swiss cantons tax inheritances to children?

Normally not. According to ch.ch, spouses, registered partners and descendants are normally exempt, and Obwalden and Schwyz levy no inheritance tax at all. Rules vary by canton.

Does a Swiss single family office need a FINMA licence?

Generally not, if it manages only assets of family-related persons; FINMA excludes that activity when assessing commerciality. Third-party management above the thresholds needs a licence.

Is Swiss lump-sum taxation still available?

Yes, in most cantons, for non-Swiss nationals who do not work in Switzerland. For 2026 the federal minimum base is CHF 435,000. Zurich, Basel-Stadt, Schaffhausen and Appenzell Ausserrhoden have abolished it.

Is banking secrecy stronger in Switzerland or Singapore?

Both protect client data with criminal sanctions under article or section 47 of their Banking Acts, and both exchange account information automatically, so neither shields assets from a home tax authority.

Sources

• ESTV: The Swiss Tax System (2025 edition)
• ch.ch: Inheritance tax in Switzerland
• FINMA: Trustees
• IRAS: Estate Duty
• Banking Act 1970 (Singapore Statutes Online)

Raffles Corporate Services helps families weighing Switzerland against Singapore with family office set-up, VCC incorporation and ongoing compliance in Singapore. Email hello@rafflescorporateservices.com or Call/SMS/WhatsApp +65 8501 7133, or visit Raffles Corporate Services.

Last reviewed: 12 October 2026. The Editorial Team, Variable Capital Companies Act.