Swiss Private Wealth Update: Inheritance Tax Referendum, Trust M&A and PTC Planning
Switzerland is grappling with a controversial inheritance tax initiative at the same time as its trust and wealth industries consolidate and international competition for mobile UHNW capital intensifies.
Update to the article 30th November 2025: the 50% inheritance tax on assets above 50mio CHF was rejected by the Swiss population today.
In Citywealth’s 2024 Switzerland update, contributors focused on transparency, EU market access and the rise of digital assets; one year on, the debate has shifted towards domestic tax politics and structural change in the trust and wealth industries.
Our panel of experts in Geneva, Zurich, London and beyond share their views on what comes next for Swiss private wealth.
Inheritance Tax Referendum: What a 50% Levy Above CHF 50m Could Mean for Switzerland
From Geneva, Gintarė Nedelec highlights how a proposed inheritance tax initiative is unsettling the market, and how this sits alongside a broader consolidation in the Swiss trust sector.
Gintarė Nedelec, Trust Officer, Guardian Trust, Geneva says, “We are currently impatiently waiting for the vote on Inheritance Tax Initiative, “for a social climate policy, financed fairly through taxation (Initiative for a future)”. It is an inheritance tax initiative which would mean 50% of inheritance and gift tax with the minimum wealth threshold for the tax to be applied CHF 50 million on all gifts and a person’s estate while suggesting using the collected funds to fight climate change.”
“The initiative would be a significant blow to the Swiss finance industry as this could prompt the wealthiest families and business owners to flee the country or high net worth individuals to not even consider Switzerland for their tax residency anymore. The federal council has rejected the initiative; however, the referendum will still take place. There is a strong effort from the Swiss government to inform voters of the devastating consequences this law might have for financial sector, however the referendum is set to take place on 30 November 2025.”
Trust Companies Under Pressure: FINMA Licensing, AML Costs and Consolidation
Nedelec also points to structural change in the trust market, driven both by regulatory enhancement and rising costs.
“It seems that the current tendency in trust industry market in Switzerland is consolidation, there have been some substantial acquisitions of trust companies and family offices in recent months (Accuro Trust (Switzerland) S.A. and Stonehage Fleming and Stanhope Capital), and it seems that this tendency might continue in near future. This is due to the introduction of FINMA’s Trust Company Licence in Switzerland, the market is more attractive, as it is now properly regulated, therefore, it attracts wealth management businesses that would like to have a presence in Switzerland. However, due to the increased AML procedures and requirements, it is becoming harder for smaller trust companies to justify the increase of administrative and compliance costs which obliges some companies to reconsider their long-term strategy. However, it seems that high-net-worth individuals still value their trusted advisors in smaller trust companies, and these have a lot to offer in terms of bespoke service with focus on building long term client relationships that last over time.”
Zurich-based tax expert Michael Fischer takes a more sanguine view of the inheritance tax proposal, and sees strong international interest in acquiring Swiss fiduciary and wealth management businesses.
Michael Fischer, Partner at law firm. Fischer Ramp Buchmann says, “On the subject of inheritance tax, I think it is reasonable to expect that the proposal will not pass. The way I see it is that a healthy debate is not wrong – although this is not one, I would necessarily have started.” On the consolidation in the trust industry. “Indeed, there is consolidation and interest from abroad to acquire first rate players. I see a similar interest in the wealth and asset manager industry. Just today, I have had lunch with a London based wealth managers who are very interested in raising their profile in Switzerland, preferably through an acquisition of the right local player.”
Swiss Wealth Hubs: Zurich vs Geneva for UHNW Clients
The choice of Swiss city still matters for business development and client focus.
“There is still the traditional divide between the Zurich and Geneva markets. In the words of that same London wealth manager ‘Zurich is where the action is’, although he did say that for Saudi and the LatAm markets it was probably more Geneva that was relevant.”
Switzerland and the EU: Insularity or Integration?
Fischer moves onto the EU, linking domestic debates back to Switzerland’s broader place in Europe.
“We are currently heavily debating a renewal of the agreements with the EU. Some, the more conservative, right wing-ish ones, think we should send the EU packing with their agreements in hand. Others are very much of the view that Swiss insularity is hardly the future.”
Who is behind the initiative and why markets expect it to fail
On the Inheritance Tax Initiative, Dr Ariel Sergio Davidoff, Founder of Davidoff Law, says, “The Juso, the Young Socialist Party of Switzerland, launched this initiative with the aim of taxing the roughly 2,500 wealthiest individuals in the country. On assets above 50 million francs (roughly 50 million GBP), as has been mentioned, the inheritance and/or gift tax would be set at 50 percent on the amount exceeding that threshold, with the revenue earmarked for Switzerland’s transition to climate neutrality. Opinion polls indicate that the proposal is set to be decisively rejected by voters, not least because both the Federal Council and Parliament recommend voting against it. At the federal level, inheritances/gifts are currently exempt from tax. The Juso also advocate nationalising Switzerland’s pharmaceutical industry and “dismantling” the country’s defence industry, positioning themselves at the extreme end of the socialist spectrum. Many Swiss voters will also have in mind the example of the United Kingdom, where the entire government believes, unlike the Swiss Parliament and government, that millionaires would not relocate if taxed. At least 3000 previously UK-based millionaires according to Henley & Partner’s moved to Switzerland, apparently with less than 50mio CHF, so there is a high chance that things will remain as they are, without these new, proposed taxes.”
Kecia Barkawi, Founding Partner of VALUEworks, a multi family office based in Zurich, agrees with Fischer and adds that a pre-election forecast in late October indicated that only one third of the voters are likely to vote for the young socialists’ initiative. She added though that the upcoming vote initiated a number of very interesting discussions with family members and their advisers. “The range of discussion is actually huge, from moral and ethical discussions, to why they live in Switzerland; if tax considerations should determine where families (or just certain members of the family) should live, or is safety so much more important today, the role taxes play in society, the importance of family cohesion, roots, what is home, the burdens of having to count your days, and what if a family member gets ill and you have ‘no more day credits’. There is a lot more on the table, and advisers I speak to have very different views.”
Dr. Markus Zwicky, Partner, at law firm Zwicky & Partner based in Zug adds his view. “Indeed the referendum on Inheritance Tax is scaring the super-wealthy and leading some to leave the country. However, there are three reasons to remain alert: 1. The Young Socialist Party who has managed to gather the signatures for this initiative do not have broad representation among the voters, but they reach the young and the urban population, especially in the Latin part of the country (referring to Italian Switzerland). Many Swiss people have had enough of HNW immigration because real estate prices make it impossible for locals to rent. 2. The threshold of 50 million does not affect most Swiss people and those affected find little sympathy with the majority. 3. Many HNWI came to Switzerland for other reasons than tax (personal and social safety, stability). They have their finances organized in trusts or structures and so it will not affect their personal assets. So not everyone will leave because of a new estate tax.”
Zurich legal view: stability, predictability and ‘institutional-grade’ trustees
Dr. iur. Reto Luthiger, Partner at law firm, MLL Legal in Zurich, also expects the inheritance tax initiative to fail at the ballot box but says that the damage is already being felt.
Luthiger says, “I also expect the inheritance tax initiative to be clearly rejected, as the first polls already indicate. Personally, I welcome this outcome, since the initiative, even during the campaign period, has already had a chilling effect on Switzerland’s wealth management sector. Stability and predictability remain key pillars of Switzerland’s attractiveness as a location for private clients and family offices.”
On the trustee side, Luthiger sees continued demand for the new FINMA trustee licence, but confirms that higher standards are forcing change. “In relation to trustee companies, we continue to see solid interest in obtaining the new FINMA trustee licence. However, the higher regulatory standards have clearly accelerated a consolidation trend towards larger and more professionally structured trustee companies. Smaller firms increasingly face challenges in coping with compliance, AML and governance requirements, whereas larger players are leveraging the new licensing framework to position themselves as trusted, institutional-grade service providers.”
How the Swiss Inheritance Tax Debate Looks from the US and Italy
Viewed from the US, the Swiss inheritance tax debate looks puzzling to some, given America’s own political climate and the competition for globally mobile UHNW families.
Joshua S. Rubenstein, Partner, Global Chair, Private Wealth, Katten, New York adds his view. “The private wealth industry in the US has been watching the pending Swiss inheritance tax initiative with some bemusement. Our incumbent administration is providing ample fodder for ultra-high net worth individuals to consider moving, and you would think that other countries would want to compete for their wealth. While until recently the tax regimes in the UK and in Switzerland had been attractive for recent UHNW arrivals to their country, recent tax changes in both countries are making Italy’s regime for moving there extremely attractive.”
However, Alessandro Belluzzo who specialises in Italian law, cautions that Italy is not a one-way bet, and that on the ground Switzerland may still come out ahead for some clients. Alessandro Umberto Belluzzo, Barrister and Founding Partner at law firm Belluzzo International Partners who have offices in the UK, Italy and the Middle East, says, “My understanding is that Italy has become more expensive and so for some people Switzerland is still a better option.”
When Does a Private Trust Company Make Sense? PTC Planning in Practice
Against this backdrop, Peter Moorhouse turns to a practical question on the minds of many families: at what level of wealth does it make sense to establish a private trust company in Switzerland?
The answer principally depends on the family’s objectives and why they want to create a a PTC says Peter Moorhouse, Managing Director, Ace International, Geneva. “A private trust company (PTC) is a company clients create to serve as the trustee for their family’s trust(s) usually with the help of a professional trustee. It is a combination of external professional management and guidance with a family input. Unlike large trust companies that serve several clients, the family PTC is not open to the public and only serves one family’ interest.”
“While they are most associated with families worth $100 million or more, families with less wealth often still benefit, especially when enhanced privacy, family governance and control, complex and diversified assets need to be managed in a more tailored approach or a long-term succession planning across generations are the family’s top priorities.”
“We administer and manage a number of PTC’s, some with significantly less than USD 100m. The infrastructure, corporate governance and controls appropriate for each PTC depends on the family and their circumstances, the assets involved and the professionals engaged. Each of the aforementioned elements impacts the cost of a running a PTC, and therefore influences the deemed assets required to make a PTC worthwhile.”
Beyond trusts: UBS, regulatory density and why Switzerland still looks solid
Too Big to Fail 2.0? UBS and the new capital debate and consolidation goes mainstream: from trusts to banks and asset managers
Davidoff sees the consolidation trend extending well beyond the trust industry. “The consolidation trend seen in the Swiss trust industry is also evident among banks and independent asset managers, as Switzerland too is experiencing an increase in regulatory density. The debate on higher capital requirements appears particularly critical for UBS, ‘too big to fail 2.0’. If the proposals currently on the table were implemented, the bank would need to raise substantially more capital than is required under the Basel III rules already in force. This is important because UBS can, of course, choose its headquarter not to be in Switzerland.”
From velvet gloves to steel: FINMA, ESG, sustainability and AML bite
He adds that the regulatory ratchet is visible across multiple fronts. “Other areas are also seeing moves toward tighter regulation. FINMA has taken off the velvet gloves and is conducting more intensive supervision. ESG/sustainability regulation is firmly on the agenda, with Switzerland looking to align itself with the EU on greenwashing, disclosure and transparency. Anti-money-laundering rules are being revised to place greater obligations on non-financial intermediaries such as lawyers and fiduciaries. Requirements around operational resilience, particularly in relation to digitalisation and cyber risks, are being strengthened, and tax transparency continues to move in the direction of OECD standards.”
Beyond the Noise: A Stable, High-Quality Hub with ‘debt brake’
Yet, in his view, the net result is still an attractive proposition.
“On the positive, Switzerland continues to stand out for all the right reasons. Political life is calm and predictable, with regulators taking a steady, pragmatic approach rather than swinging between extremes. Businesses benefit from clear processes, reliable institutions and a culture that prizes quality over grandstanding. Innovation is alive and well, anchored by world-class universities and a highly skilled workforce, yet never wrapped in hype. The financial centre has adapted smoothly to international standards and now presents itself as a mature, well-regulated hub that still offers a reassuring sense of continuity and performance-orientation. High living standards, excellent infrastructure and strong property rights round out a picture of a jurisdiction that remains both modern and remarkably solid. A testament to this stability is the continued strength of the Swiss franc, supported by Switzerland’s continued application of a ‘debt brake’, in contrast to the United States and the EU.”
Swiss Divorce Planning for HNWIs: New Court Rulings Change the Game
Zwicky, a legal specialist in corporate and private client, with a focus on marriage and inheritance law, adds a further comment. “Recent trends for the UHNWi in divorce planning include the Swiss Federal High Court ruling that a spouse cannot rely, any more, on having their ongoing lifestyle financed (conditions and exceptions apply for that). Spouses are now expected to go back to work, even if there are joint children. Switzerland therefore is definitely not a divorce haven for HNWI when it comes to marital assets. Child alimony is also as high as anywhere else, so if an UHNWi absolutely wants to live in Switzerland, carefully think about divorce planning.”
Switzerland’s Wealth Model on Trial: What to Watch Next
The picture that emerges is not of a centre in decline, but of one in negotiation with itself. A politically charged inheritance tax proposal, a stricter licensing and AML environment and a steady run of deals in the trust and wealth sector are all forcing choices, for policymakers, for firms and for families. As Davidoff and others suggest, Switzerland still offers what many UHNW clients are looking for: experienced advisers, deep ecosystems in both Zurich and Geneva, and a stable, rules-based environment. The question for the next few years is how far the electorate and the EU debate will allow that model to evolve without undermining the qualities that made the jurisdiction attractive in the first place.
Gintarė Nedelec’s Citywealth Leaders List Profile
Guardian Trust’s Citywealth Leaders List profile
Michael Fischer’s Citywealth Leaders List profile
Fischer Ramp Buchmann’s Citywealth Leaders List profile
Dr Ariel Sergio Davidoff’s Citywealth Leaders List profile
Davidoff Law’s Citywealth Leaders List profile
Kecia Barkawi’s Citywealth Leaders List profile
VALUEworks AG’s Citywealth Leaders List profile
Dr. iur. Reto Luthiger’s Citywealth Leaders List profile
MLL Legal’s Citywealth Leaders List profile
Joshua S. Rubenstein’s Citywealth Leaders List profile
Katten Muchin Rosenman’s Citywealth Leaders List profile
Peter Moorhouse’s Citywealth Leaders List profile
Ace International SA’s Citywealth Leaders List profile
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FAQ:
The initiative—launched by the Young Socialist Party (Juso)—proposes a 50% inheritance and gift tax on wealth above CHF 50 million, with proceeds earmarked for climate-transition measures.
The proposal has unsettled UHNW families, trustees and advisers because:
It could incentivise wealthy individuals to leave Switzerland or avoid relocating there.
It disrupts Switzerland’s reputation for stability and predictability in wealth planning.
Even the campaign period has had a chilling effect on private-wealth sentiment.
The referendum is scheduled for 30 November 2025.
Most experts expect it to fail decisively.
Key reasons:
Both the Federal Council and Swiss Parliament recommend voting against it.
Polling already shows significant resistance.
The initiative targets only ~2,500 people, giving it limited mainstream support.
Many Swiss voters are wary of Juso’s broader agenda, including nationalising pharma and dismantling the defence industry.
However, some caution that:
Younger and urban voters may be sympathetic.
Rising frustration with HNW immigration and housing-price pressures could influence turnout.
Even if rejected, the initiative has already:
Triggered relocations among the super-wealthy.
Created uncertainty about the long-term tax direction.
Reinforced concerns that Switzerland’s tax stability may be increasingly subject to populist politics.
Stability — a core selling point — feels temporarily weakened.
The sector is undergoing significant consolidation driven by:
The introduction of FINMA’s trustee licence, which raises governance and regulatory expectations.
Higher AML, compliance and administrative costs that smaller firms struggle to absorb.
Acquisition activity from major players such as Accuro Trust, Stonehage Fleming and others.
Despite consolidation, many clients still value boutique, relationship-driven trust companies.
Because Switzerland:
Remains a sought-after wealth hub.
Now offers a fully regulated trustee framework, attractive for institutional buyers.
Has a large pipeline of retiring founders or successors seeking exit opportunities.
Provides a strong asset base of international private-wealth clients.
London-based managers, US groups and European acquirers are particularly active.
Both matter — but for different markets.
Zurich: “Where the action is”. Preferred by general UHNW wealth managers and corporate-finance-driven families.
Geneva: Favoured for Saudi, Middle Eastern and Latin American private clients.
The city split remains a defining feature of Swiss private-wealth strategy.
Switzerland is again debating renewal of bilateral agreements with the EU.
Two opposing views are prominent:
Insularity camp: Switzerland should resist EU pressure and maintain sovereignty.
Integration camp: Economic and regulatory alignment is essential for long-term competitiveness.
This political tug-of-war influences perceptions of Switzerland’s openness, economic positioning and regulatory future.
The Young Socialist Party (Juso).
Their goals include:
Taxing the very wealthiest individuals.
Using funds for climate neutrality.
Pursuing broader structural reforms such as nationalisation of key industries.
Their platform is at the far-left end of Swiss politics and does not reflect broader parliamentary views.
Some are already doing so, but experts offer three balancing observations:
Juso’s base is narrow, mainly young and urban voters — national approval is unlikely.
The tax threshold (CHF 50m) affects very few residents, reducing mainstream political pressure.
Many UHNW families are in Switzerland for safety, stability and lifestyle, not solely tax.
Many use trusts or PTC structures that may insulate assets.
So while departures are real, a wholesale exodus is unlikely.
Key trends include:
High interest in FINMA trustee licences, especially among larger or institutional firms.
Smaller companies face compliance and AML pressure and may exit or merge.
FINMA has “removed the velvet gloves” — conducting more intensive oversight.
ESG, sustainability and anti-greenwashing rules are rising to EU levels.
Operational resilience rules (digitalisation, cyber risk) are tightening.
Switzerland is shifting from “light-touch” to high-quality, highly supervised wealth management.
A Private Trust Company (PTC) is:
A dedicated company created to act as trustee for a single family’s trusts.
Operated with support from professional trustees.
Designed for privacy, governance participation and complex asset management.
While often linked to families of $100m+, many families below that level establish PTCs when they need:
Enhanced privacy
Better family governance
Management of complex or diversified assets
Long-term succession planning
Cost, structure and governance levels vary by family circumstances.
Recent Swiss Federal High Court rulings have changed expectations:
A spouse can no longer rely automatically on maintaining their ongoing lifestyle.
Even with children, spouses are expected to return to work (subject to conditions).
Switzerland is therefore not a divorce-friendly jurisdiction for HNWIs seeking generous long-term maintenance.
Child support obligations remain high.
HNW families are now planning divorce-risk scenarios more carefully when choosing Switzerland as a base.
Key themes to monitor include:
The 2025 inheritance-tax vote
EU negotiations and potential new agreements
Continued trust and wealth-manager consolidation
Tightening AML rules for non-financial intermediaries
Implementation of ESG/greenwashing regulation
UBS capital rules and potential headquarter implications
Evolving expectations around operational resilience
Family-governance shifts, including PTC adoption trends
Switzerland’s wealth sector is adjusting — but the underlying model remains robust.
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