A paradise for foreign capitalists? Expenditure-based taxation in Switzerland, 1916–2020

Abstract Expenditure-based taxation ( forfait fiscal/Pauschalbesteuerung ) is a distinctive Swiss tax regime under which wealthy non-working foreign residents are taxed according to their estimated living expenses and not, as ordinary taxpayers, on their income or wealth. Drawing on new sources, we analyse the emergence, expansion, and resilience of this tax regime. We show how it became embedded in cantonal tax systems despite repeated criticism from federal authorities and the international community. Expenditure-based taxation was not used to generate tax revenues but to boost high-end sedentary tourism and wealth management services. Intermediaries played a key role in the domiciliation of wealthy foreigners benefitting from such schemes. Besides offering a fresh perspective on Switzerland’s role as a tax haven for wealthy individuals, we shed light on the legal, political, and professional networks that sustain tax privileges and discuss broader issues linked to tax justice and the governance of international wealth.