Relocating to Switzerland 2026: Unlimited Deferral of German Exit Tax — and Why a Second Passport Matters

Why is Switzerland uniquely treated under German exit tax — unlike the UAE, USA or the Caribbean?

The standard model in German tax practice is straightforward: relocation to the EU/EEA = deferral, relocation to a third country = immediate payment. That simplification holds for most third countries — but not for Switzerland.

The Germany–Switzerland double taxation agreement (originally 1971, last revised in 2011) contains specific provisions on capital gains and mutual administrative assistance. The BMF has confirmed in its administrative practice that, on relocation from Germany to Switzerland, the §6 AStG exit tax does not become immediately due. Instead, the tax is treated as deferred — without limit, without interest — until the actual sale of the affected holdings.

The reason: the Germany–Switzerland DTA secures the administrative assistance and information exchange Germany requires under OECD standards for such a deferral arrangement. Switzerland has been compliant with the OECD's automatic exchange of information (AEOI) since 2017 — and that standard is the very prerequisite for the favourable BMF administrative practice.

Further analysis: Federal Ministry of Justice — §6 AStG full text (gesetze-im-internet.de) | Henley Global Mobility Report — international tax residence trends

Mirabello guide: German Exit Tax on ETFs 2026: §6 AStG for fund investors — full guide →

What does the unlimited deferral concretely mean for relocations to Switzerland?

By way of reminder: §6 AStG was extended by the German Annual Tax Act 2024, with effect from 1 January 2025, to ETF units and investment fund units. Since then it covers three categories:

• Category 1 (long-standing): Shareholdings in corporations from 1 % participation onwards (§17 EStG) — for example GmbH stakes and unlisted corporate holdings
• Category 2 (new since 2025): ETF units and UCITS funds under §§18, 19 InvStG — for example MSCI World and S&P 500 ETFs
• Category 3 (new since 2025): Units in special investment funds — common in family-office structures

For all three categories, the Swiss special rule applies: relocating to Switzerland defers the §6 AStG tax. The following obligations must be observed, but no payments are due:

• Filing a §6 AStG notification with the competent German tax office in the year of departure
• Since January 2026: use of the new BMF form "ASt – Mitteilung" via the BMF tax portal
• Annual reporting on the continued holding of the units, for as long as the deferred tax has not been assessed
• Notification of the actual disposal to the German tax office once the holdings are realised

What happens when the holdings are sold while you are resident in Switzerland? The German exit tax originally calculated in the year of departure becomes payable — based on the deemed disposal gain at the time of relocation, not on the later actual sale price. If the value of the holdings has fallen in the meantime, an application for adjustment may be filed. If it has risen, the lower exit tax assessed in the year of departure remains binding — a real financial benefit for strongly appreciating ETF positions.

What additional Swiss tax advantages apply to German emigrants?

For a German investor with a substantial ETF portfolio, the practical advantage is striking:

In Germany (before relocation): Future ETF gains after relocation would attract 26.4 % flat capital gains tax (where still subject to German taxation).

In Switzerland (after relocation): Future appreciation realised on the disposal of ETFs and shares held privately: zero per cent tax — provided no commercial trading activity exists. Dividend income is subject to Swiss income tax, which, depending on canton and tax base, sits considerably below the German level.

Concretely: an investor who sells an ETF portfolio worth CHF 3 million with an embedded gain of CHF 1.5 million after relocating to Switzerland pays zero Swiss tax on that gain. The German exit tax deferred on the value at the date of departure becomes payable on disposal — but the entire post-relocation appreciation remains tax-free in Switzerland.

This is a structural advantage over Malta (non-dom only covers non-remitted income), Cyprus (zero CGT applies but with a 60-day rule) and Portugal (NHR 2.0 covers qualifying activities only). Switzerland offers the benefit by default to all private investors — no application, no qualifying conditions, no minimum-stay obligation beyond actual tax residence.

What is the Swiss lump-sum tax (Pauschalbesteuerung) and is it relevant for Germans?

For German nationals relocating to Switzerland for the first time (or after at least ten years of absence), the lump-sum regime is a highly attractive option — provided no gainful employment is taken up in Switzerland. The mechanism:

• Tax base: Minimum of five times annual housing cost, or at least CHF 435,000 per year at federal level
• Cantonal layer: Most cantons set their own minimum tax bases. Preferred cantons such as Schwyz, Obwalden, Nidwalden and Zug sit, in part, below CHF 250,000 [VERIFY cantonal 2026]
• No disclosure of worldwide income or assets to the Swiss authorities is required
• Not permitted: Gainful employment in Switzerland is excluded — including managing-director roles in a Swiss GmbH
• Requirement: Genuine Swiss residence (primary or secondary residence with actual physical presence)

Compared with other EU options, the advantage is clear: Greece imposes a CHF 100,000 per year lump-sum tax and Portugal's NHR 2.0 is restricted to qualifying activities. Swiss Aufwandbesteuerung in preferred cantons delivers the lowest effective rates available to non-active high-net-worth individuals — without any activity requirement.

Compare residence programmes: Best Golden Visa Programmes 2026 — comparison for German investors →

Which Swiss cantons are most attractive for German HNWI emigrants?

Switzerland's tax appeal varies considerably across cantons. For German emigrants with substantial wealth, the following are particularly relevant:

[VERIFY: Current cantonal lump-sum minimums 2026 — variations possible. Individual advice from a Swiss tax adviser is required.]

Mirabello Consultancy is headquartered in Zurich and maintains an active network of tax advisers in Zug, Schwyz and other preferred cantons. We coordinate the optimal cantonal structure for each client individually.

How does the strategic combination work: relocation to Switzerland plus a second citizenship?

Since the German citizenship reform of June 2024 (Act on the Modernisation of Citizenship Law), German nationals may acquire a second citizenship without losing the German passport — no special permit required. Demand for CBI programmes among German HNWIs has grown considerably as a result.

For those relocating to Switzerland and establishing tax residence there, the combination delivers:

• Swiss residence status: tax residence in Switzerland, deferral of the German exit tax, zero CGT on private securities held in Switzerland
• CBI citizenship: visa-free travel, contingency plan, passport-independent mobility — complementary to the German and, in time, possibly the Swiss passport

Relevant CBI options for Mirabello clients in Switzerland 2026:

• Vanuatu DSP — USD 130,000: The fastest CBI worldwide (30–60 days). No residence requirement. Note: EU Schengen visa-free access currently suspended since December 2024.
• Grenada — USD 235,000: 144+ visa-free destinations including the UK, Schengen and Singapore. The only Caribbean programme with US E-2 investor visa access.
• St. Kitts — USD 250,000: 157 visa-free destinations. US FinCEN advisory lifted February 2026 — banking access materially improved.
• Dominica — USD 200,000: The most cost-effective Caribbean CBI after São Tomé and Nauru. 140+ visa-free destinations. Note: US B1/B2 visa validity restricted to three months under US Proclamation 10998.

All CBI programmes at a glance: Best Citizenship by Investment Programmes 2026 →

Prefer residence over citizenship? Greece Golden Visa 2026: €250K start-up route — an ideal complement for Swiss residents →

The strategic sequence: what should German HNWIs do — and when?

For German HNWIs with a substantial ETF portfolio and an emigration plan, Mirabello Consultancy recommends the following sequence:

1. Step 1 — Stocktake (today): Portfolio review: which ETF and fund positions exist? What are the unrealised gains? What does the §6 AStG calculation produce? This yields the tax amount potentially deferred in the year of departure.
2. Step 2 — Cantonal strategy (3–6 months): Selection of the optimal Swiss canton based on lifestyle, tax conditions and lump-sum options. Coordination with a Swiss tax adviser. Preparation of property rental or purchase.
3. Step 3 — Formal relocation (12–18 months): Formal de-registration in Germany and registration in Switzerland. Shift of the tax centre of life. Filing of the §6 AStG notification with the German tax office (including BMF form "ASt – Mitteilung"). The deferred exit tax arises at this point — but no immediate payment is due.
4. Step 4 — CBI application (in parallel or after relocation): Application for a second citizenship through a suitable CBI programme. The application can be filed before or after the Swiss move — citizenship is independent of the tax planning.
5. Step 5 — Realise the ETF portfolio gradually (long term): Gains realised in Switzerland on ETF disposals are tax-free across the federation. The German deferred exit tax becomes due on actual disposal — the timing is entirely in your hands.

An example: an investor with a CHF 2 million ETF portfolio (unrealised gain CHF 1.2 million) relocates to the canton of Schwyz in 2026. The deferred §6 AStG tax: approximately CHF 317,000. He sells the portfolio in tranches over ten years and pays the deferred tax pro rata. Every Swiss franc of gain accruing after relocation: tax-free in Switzerland. His CBI passport (Grenada, CHF 235,000): secures global mobility and a contingency plan for the next generation.

Frequent questions Germans ask about relocating to Switzerland in 2026 — and how Mirabello answers them

Does the unlimited deferral on relocation to Switzerland also apply to the new ETF extension since January 2025?
Yes — BMF administrative practice and the Germany–Switzerland DTA cover all §6 AStG triggers, including the ETF and investment fund units captured since 1 January 2025. The Annual Tax Act 2024 extension did not narrow the Swiss special rule. [VERIFY: A formal BMF circular specifically addressing the ETF extension is pending — until issued, treated as confirmed under administrative practice.]

Do I still owe German tax on selling ETFs after relocating to Switzerland?
Yes — when you dispose of holdings that fell within §6 AStG at the date of relocation, the deferred exit tax becomes payable. It is calculated on the deemed disposal gain at the time of departure. If the value has fallen, you may apply for a value-loss adjustment. For appreciation arising after relocation and realised in Switzerland: zero Swiss tax, and these post-departure gains are not part of the German liability.

Can I apply for CBI citizenship after relocating to Switzerland?
Yes. CBI programmes are entirely independent of your tax residence. As a Swiss resident you may apply to any CBI programme worldwide — Grenada, St. Kitts, Dominica, Antigua, Vanuatu and others. Mirabello Consultancy administers the application from Zurich. Since the German citizenship reform (June 2024), German nationals may acquire a second citizenship without losing the German one.

Must I lodge a security deposit with the German tax office for the Swiss deferral?
No. The Swiss special rule does not require a security — unlike most other third countries (UAE, USA, Caribbean), where a seven-year instalment deferral is only available under strict conditions and with security deposits. The Swiss deferral is structurally aligned with the EU/EEA standard: no payment, no security, no interest until the actual disposal.

How do I begin planning a Swiss relocation with Mirabello Consultancy?
The first step is a free initial consultation with our experts in Zurich. We analyse your portfolio, your relocation goals and the cantonal options — then build an individual roadmap. Mirabello Consultancy is headquartered in Zurich and coordinates the full emigration architecture: §6 AStG planning, Swiss cantonal setup, CBI application and ongoing support. Book your free consultation →