Relocating from Switzerland to Singapore

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A founder who moves from Zug to Singapore faces a sequence of questions on each side. On the Swiss side, residence ends when the founder gives up his Swiss domicile and the cantonal tax office accepts the departure. Swiss tax liability for the year is apportioned to the date of departure. Switzerland imposes no exit tax on private individuals, so unrealised token gains are not taxed on leaving. The Swiss wealth tax ends with the departure. A founder who held his tokens as private wealth leaves with no Swiss tax on them. A founder who was classed as a professional trader has his final-year trading income assessed and his social security contributions settled.¹ Shares in a Swiss company held by the departing founder remain subject to Swiss withholding tax on dividends, with treaty relief under the DTA (Chapter IX of this Part).

On the Singapore side the founder becomes resident from arrival under the administrative concessions if he stays more than 183 days across the two years. His tokens acquired before arrival have a cost base equal to their original cost, because Singapore has no step-up on arrival, but that is irrelevant if he is an investor and never taxed on the gain. If he is a trader, IRAS taxes the gains realised after arrival on the full difference between proceeds and original cost, which can include appreciation that occurred while he was Swiss-resident. The way to avoid double counting is to realise the trading book before departure, which Switzerland does not tax if the founder was a private investor and does tax if he was a professional trader. The sequence of realisation is therefore planned around the Swiss classification.

Cross-border perspective

A founder leaving Zug for Singapore should ask the cantonal tax office for a ruling on his status as private investor before departure. He should realise or rebalance in the final Swiss year while the ruling protects him and document the token values at the departure date. He should arrive in Singapore with a clean separation between long-term holdings and any trading book. The Singapore Employment Pass or ONE Pass application should be filed before departure so that residence in Singapore begins without a gap. A gap produces a period of no residence anywhere during which neither treaty protects him and his bank will ask uncomfortable questions.

Notes

Direct Federal Tax Act (DFTA; DBG), SR 642.11, Art. 8 para. 2 (end of tax liability on departure) and Art. 16 para. 3 (exemption of private capital gains). Switzerland has no general exit tax for individuals. ↩

For general information only. This article does not constitute legal or tax advice, does not replace advice on an individual case and creates no lawyer-client relationship. It reflects the legal position as of October 2026.

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Dr Alexander Ressos, TEP

Of Counsel, KGP Legal LLC

I am Of Counsel with KGP Legal LLC in Singapore, where I work with a global client base of successful entrepreneurs and their families, independent asset managers, commodity trading houses and other commercial clients. I am a German and Swiss attorney-at-law, also admitted as a solicitor in England & Wales and in Hong Kong. I divide my time between Zug in Switzerland, Singapore and Hong Kong. Since 2017 I have advised international clients on more than 700 crypto and digital asset projects. I also have extensive experience in cross-border litigation and arbitration in Singapore, Hong Kong and other markets in South-East Asia and Greater China.

I operate across the key financial centres in South-East Asia, the Middle East and Switzerland, with a particular focus on asset protection, international tax and estate planning, as well as trusts, company administration and other fiduciary services. My philosophy is to serve as a trusted advisor working closely with my clients and to help them achieve their commercial objectives.

All Singapore law advice is provided through KGP Legal LLC, an established and duly licensed firm of Singapore advocates and solicitors.

KGP Legal LLC is a medium-sized law firm in Singapore that is capable of providing the full range of legal services and corporate administration work. Please contact me directly at [email protected] if you need any further information.

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SingaporeIQ is edited by Dr Alexander Ressos, an international business lawyer with more than 15 years of local experience in Singapore as a permanent resident, a Singapore registered foreign lawyer and managing partner of a Singapore foreign law practice. In addition to significant experience in cross-border investments and transactions, UHNWI private client work and sanctions/export controls, Dr Ressos has extensive experience in cross-border business and in crypto and digital-asset projects in Singapore, drawn from more than 700 projects since 2017.

If you are planning a company incorporation, an investment, a holding structure or a market entry through Singapore, you can reach Dr Ressos directly at [email protected]. Singapore law advice is provided by KGP Legal LLC, a licensed firm of Singapore advocates and solicitors. As a Singapore law practice, KGP Legal LLC is authorised under the Legal Profession Act 1966 to advise on Singapore law and to represent clients before the Singapore courts; foreign law practices with an office in Singapore are, as a rule, not permitted to do either. Dr Ressos and his team facilitate the full range of Singapore legal, compliance and company administration services, including company incorporation, corporate transactions, commercial contracts, crypto and digital assets, financial regulatory work and dispute resolution, including litigation in the Singapore courts. For legal, tax and fiduciary services in Switzerland, see helveticaregister.com.