Most tax systems operate on a simple principle: The more you earn, the more you pay. For multimillionaires, this means watching a substantial portion of income disappear into government coffers each year. Lump-sum taxation flips this model entirely.
Under lump-sum taxation, sometimes referred to as flat-rate or expenditure-based taxation, you pay a fixed annual amount regardless of how much you actually earn. If your foreign income totals €500,000 or €50 million, your tax bill stays the same. For those with eight-figure incomes, the math becomes extraordinarily favorable.
Three European countries currently offer lump-sum taxation programs that grant residency alongside tax benefits: Switzerland, Italy, and Greece. Each structures its program differently, and the right choice depends on your wealth level, income sources, and lifestyle preferences.
A Caribbean nation also makes this list, with a sophisticated lump-sum taxation framework.
Switzerland: The Original Forfait Fiscal
Switzerland pioneered lump-sum taxation for wealthy foreigners, and its program remains among the most established in the world. Known locally as the forfait fiscal, this expenditure-based system calculates your tax liability based on living expenses rather than actual income.
The Swiss approach differs from flat-rate programs elsewhere. Instead of paying a single fixed sum, you pay taxes on an assumed income derived from your lifestyle spending.
The tax base equals the highest of several measures: Seven times your annual rent, three times your hotel costs if you live in accommodations, or a federal minimum of CHF 434,700 (approximately $490,000) as of 2025.
In practice, this formula produces minimum annual tax bills ranging from CHF 250,000 to CHF 1 million, depending on which canton you choose.
Data from Switzerland’s State Secretariat for Migration shows 496 non-EU nationals held lump-sum tax residence permits as of March 2025, a 22% increase from the previous year. Russians comprise the largest nationality group at 20%, followed by Chinese and British nationals at 10% each, and Americans at 8%.
Canton selection matters considerably. Geneva hosts one quarter of all lump-sum tax residents and attracts the largest share of applicants. Valais follows at 12%, Ticino at 11%, and Vaud at 9%. Obwalden offers the lowest entry point at approximately CHF 250,000 in annual taxes, while Zug demands CHF 1 million.
Not all cantons participate. Zurich abolished lump-sum taxation in 2010 following a public referendum, and Basel followed in 2012. The 16 individuals still registered in these locations represent grandfathered cases from before abolition.
To qualify, you must hold foreign (non-Swiss) citizenship, take up residence in Switzerland for the first time or return after at least ten years abroad, and refrain from working in the country.
The route provides temporary, renewable residence permits for wealthy individuals, and is the closest thing Switzerland has to an investment migration program.
The pathway targets passive income earners and those managing wealth from foreign sources. Any Swiss employment or business activity disqualifies you immediately.
Italy: The €300,000 Flat Tax
Italy introduced lump-sum taxation in 2017 and has since become one of Europe’s most popular destinations for relocating millionaires. The program works differently from Switzerland’s expenditure-based model. You pay a fixed annual substitute tax on all foreign-sourced income, full stop.
The price has increased twice in recent years. Italy originally set the flat tax at €100,000 annually. In August 2024, it doubled to €200,000. Then, with the approval of the 2026 Budget Law on December 30, 2025, Italy raised the rate again to €300,000.
Family members can participate too. The flat tax for qualifying relatives increased from €25,000 to €50,000 per person under the same reform. This increase applies only to those applying after January 1, 2026, not to those grandfathered at earlier rates.
Italy has consistently applied grandfathering provisions with each increase. If you transferred your tax residence before a rate hike took effect, you continue paying the rate in force at the time of your relocation for the full 15-year duration of the program. Those who moved before August 2024 still pay €100,000 annually. Those who relocated between August 2024 and December 2025 pay €200,000.
To qualify, you must not have been an Italian tax resident for at least nine of the previous ten years. Any nationality can apply, including Italian citizens returning from extended periods abroad. The program covers all foreign-sourced income: Dividends, capital gains, interest, rental income, and pensions from outside Italy.
The benefits extend beyond income tax simplification. Participants gain exemption from Italian wealth taxes on foreign real estate and financial assets held abroad. You face no reporting obligations on overseas holdings and no gift or inheritance tax on transfers of assets located outside Italy.
For families engaged in intergenerational wealth planning, these exemptions can prove more valuable than the income tax savings alone.
Income earned within Italy falls outside the flat tax and faces standard progressive rates up to 43%. The program works best when nearly all your income originates from foreign sources.
At €300,000 annually, the Italian flat tax makes financial sense for individuals or families earning roughly €1 million or more per year from abroad. Below that threshold, standard Italian taxation might actually cost less.
Greece: Tiered Options for Investors and Retirees
The Greek Non-Dom Regime for Investors requires a minimum €500,000 investment in Greek assets, including real estate, businesses, securities, or shares of Greek companies. In exchange, you pay a flat €100,000 annually on all foreign-sourced income for up to 15 years, regardless of amount.
Family members can participate for an additional €20,000 per adult annually. Those included under the family extension also receive exemption from Greek inheritance and gift taxes on foreign assets.
The eligibility requirements mirror other European programs. You must not have been a Greek tax resident for seven of the eight years prior to relocation, and you must transfer your tax residence from a country with a tax treaty or administrative cooperation agreement with Greece.
Anguilla: Caribbean Lump-Sum with Minimal Presence
Anguilla offers the most straightforward lump-sum structure outside Europe. Pay $75,000 annually on worldwide income, invest at least $400,000 in Anguillan real estate, and spend 45 days per year on the island. Your global tax obligation to Anguilla ends there.
The High Value Resident (HVR) Program requires that you not spend more than 183 days in any other single jurisdiction. This prevents you from establishing tax residence elsewhere while maintaining Anguilla’s favorable treatment. Meet these conditions, and Anguilla imposes no income tax, corporate tax, capital gains tax, or inheritance tax beyond the annual $75,000 payment.
Choosing the Right Program
Governments can change these programs at will. Italy has already raised its flat tax twice in two years. Switzerland has seen multiple cantons abolish lump-sum taxation through popular referendums.
The United Kingdom dismantled its centuries-old non-dom regime in April 2025, sending approximately 70,000 wealthy individuals searching for alternatives, and replaced it with a four-year Foreign Income and Gains (FIG) system that allows only new arrivals to bring foreign income tax-free for four years.
The regime had allowed foreign income to remain exempt from UK income tax unless remitted, and foreign assets escaped UK inheritance tax entirely.
Before committing to any program, work with qualified tax advisors in both your current country and your target destination. Lump-sum taxation can deliver substantial savings for the right profile. The wrong choice can prove expensive.
