Estate Planning in Switzerland (UK Nationals)
Switzerland is unusual in two respects: inheritance tax is set by canton, not federally, and most cantons exempt direct descendants and spouses entirely. For UK clients who relocate to Geneva, Zurich or Zug — often via lump-sum taxation or a senior corporate role — the local position is gentle. The UK side, as ever, runs by its own rules.
The cantons don't tax your children. The UK does.
Most Swiss cantons exempt spouses and direct descendants from inheritance tax. The UK exempts neither. UK domicile, not Swiss residency, decides whether 40% applies on your worldwide estate.
Inheritance tax in Switzerland is cantonal. Almost every canton — including Geneva, Zurich, Zug and Vaud — exempts spouses and direct descendants from inheritance tax. Schwyz and Obwalden go further and exempt all heirs. For Swiss-located assets passing to immediate family, the local position is genuinely favourable.
UK IHT does not see this. UK domicile, which is sticky and difficult to shed, holds most British clients in Switzerland inside the UK IHT net for years after the move — particularly clients who relocated for senior corporate roles and retain UK family ties, UK property or UK pension assets. From April 2025 the new long-term UK resident rules add further structure to when UK IHT exposure ends.
From April 2027 unused UK pensions enter the UK IHT estate. Swiss pillar-2 and pillar-3 pension assets remain governed by Swiss rules, but UK-source pensions retained from earlier UK careers — common among Swiss-based finance, pharma and tech professionals — fall squarely inside the UK 40% bracket on death above the nil-rate band.
Lump-sum taxation (forfait fiscal)
Available in several cantons including Vaud, Valais, Geneva (with restrictions) and Ticino, lump-sum taxation taxes the client on a deemed expenditure base rather than worldwide income. Genuinely valuable for clients with substantial international income who do not work in Switzerland. Has no effect on UK IHT, which is determined by UK domicile.
Swiss forced heirship (Pflichtteil)
Swiss law reserves a portion of the estate for spouses and descendants. A 2023 reform reduced the reserved share for descendants from three-quarters to one-half of their statutory entitlement, giving clients more disposable freedom. For British nationals resident in Switzerland, an English-law election under Swiss private international law is sometimes possible — we coordinate with Swiss notaries on this where needed.
Cross-border families across Switzerland and the UK
We see this regularly: a British executive in Zurich with a UK property let to fund the children's UK schooling, a Swiss spouse, and adult children moving back and forth. Each combination produces a different planning answer. The constant is that the UK side needs an English will, an English LPA and a clear IHT plan — all coordinated with the Swiss-side documents.
Where we typically come in
UK Inheritance Tax Planning
Built around the April 2027 pension change, the long-term UK resident rules from April 2025, and any UK property or business interest retained.
Read more →English Wills (and Swiss coordination)
An English will for UK assets, coordinated with your Swiss notary or lawyer for any Swiss-located property or accounts.
Read more →Lasting Power of Attorney
An English LPA for UK assets and decisions. Switzerland has its own Vorsorgeauftrag / mandat pour cause d'inaptitude — both are needed, neither replaces the other.
Read more →Property Trusts (UK)
For UK property retained on let or for family use, a Property Trust on the UK will protects the deceased spouse's share against UK care-fee assessment and unintended onward transfer.
Read more →What we'd actually do for you
First call is free, by video. We read your existing English will, any Swiss will or pacte successoral, the UK property and pension paperwork, and tell you what currently happens on death. From there we draft the English-side documents and coordinate with your Swiss notary on the local side. Most British clients in Switzerland need the UK pension piece restructured ahead of 2027 and the will updated to reflect the cross-border family.
Complete the Discovery first - then we'll book your free 30-minute consultation.
Common questions from clients in Switzerland
Most Swiss cantons don't tax inheritance to my children. Why plan?
Because UK IHT does — at 40% on the worldwide estate of a UK-domiciled person. Swiss residency does not, on its own, end UK domicile, and most British clients in Switzerland remain UK-domiciled for years after the move. The Swiss exemption is real for the Swiss side. The UK side is unaffected.
I'm on lump-sum taxation. Does that change my UK position?
No. Lump-sum taxation is a Swiss income-tax election. UK IHT is determined by UK domicile rules and is independent of how you are taxed in Switzerland on income.
Do I need a Swiss will?
For Swiss-located real property and accounts, almost always yes — drafted to coexist with the English will so neither revokes the other. We coordinate with Swiss notaries on the local side.
Do I need to come to your office to work with you?
No. We work nationally — and increasingly internationally. Most of our clients in Switzerland are seen by video call, with documents signed remotely or couriered when wet signatures are needed. The advice is the same. The convenience is yours.
Is Sean Kiani regulated?
Sean Kiani is a member of the Society of Will Writers and holds full Professional Indemnity Insurance. Estate planning is unregulated in the UK — which is precisely why credentials, supervision and indemnity matter.
What does a first conversation cost?
Nothing. A first call is free, confidential, and exists for one purpose: to find out whether your current arrangements still do what you think they do. If they do, we'll tell you. If they don't, you'll know exactly what's exposed and what to do about it.
Your 30 minutes. Simple. Yours.
No-obligation.
The path is simple: complete the Discovery first so we walk into the call already knowing the facts. Then in 30 focused minutes, I listen, answer your questions, and you choose if you'd like us to draw up your Inheritance Plan.
1. Start Your Discovery
Required first step. Complete the confidential financial position review so your no-obligation 30-minute consultation starts with the facts, not the basics.
2. Request a Callback
Prefer to speak first? Leave your details and we'll call you back to talk through the Discovery before you complete it.
You choose the date, time, and format - phone or online. Bring anyone you'd like.