On 6 April 2025, the United Kingdom abolished the regime that had, for two centuries, retained part of its wealthy population. Geneva has since featured on every list of alternative destinations. But between deciding to leave and holding the keys to a house in Cologny, there is a sequence of operations that many discover too late — and that costs months.
What has changed in London
The remittance basis regime — which allowed UK resident non-domiciled individuals to be taxed on their foreign income only when they remitted it to the UK — has been abolished. The UK government’s website puts it plainly: “On 6 April 2025 the 4-year foreign income and gains regime replaced the remittance basis.”
What replaces it is considerably narrower. The 4-year foreign income and gains (FIG) regime requires being within the first four years of UK tax residence, after at least ten consecutive years of non-residence. Beyond this period, all UK residents are taxed on their worldwide income and gains as they arise, rather than when they are remitted.
For a family that has lived in London for fifteen years, the consequence is immediate: the regime they benefited from no longer exists, and the one that replaces it is not open to them.
Inheritance follows, and it has a long tail
The income tax regime is only half of the reform, and for many families it is the other half that decides the departure. Since 6 April 2025, UK inheritance tax has moved away from the domicile test to the residence test: the deemed domicile rules are replaced by those of the long-term UK resident.
The definition is precise. The UK government states it as follows: “You are a long-term UK resident in a tax year if you are tax resident in the UK for either: the previous 10 years consecutive years [or] a total of 10 years or more within the previous 20 years.” Once in this category, it is worldwide assets that fall within the scope of UK inheritance tax — not only assets located in the UK.
And this is the point that few people anticipate: leaving the country does not close the door immediately. “You can still keep long-term UK residence for up to 10 tax years after you leave the UK.” The length of this tail depends on the duration of the prior stay — it ranges from three to ten years.
In practical terms, for a family settling in Geneva after fifteen years in London: Swiss residence may be effective, the tax deal negotiated, the house purchased — and the estate can remain linked to the UK for a decade. This does not call the Geneva project into question; it simply requires that the property acquisition be planned together with inheritance advice, and not after it. The question of “in whose name, and in what structure” arises before the deed, not at the moment of signing it.
Why Geneva — and what Geneva does not resolve on its own
Switzerland offers taxation based on expenditure, commonly known as the forfait fiscal. This is a genuine reason for relocating, but it is neither a right nor a formality: it is negotiated with the cantonal tax authorities, it requires not engaging in gainful employment in Switzerland, and Geneva applies it more strictly than other cantons. Our guide to the Geneva forfait fiscal sets out the conditions in detail.
What the forfait fiscal does not address at all, however, is the right to buy. These are two different administrations, two procedures and two timelines — and that is where projects go off track.
The order of operations, and the mistake that costs months
The natural instinct is to buy first, since the property becomes available, and to move afterwards. In Switzerland, it is the reverse.
The federal act on the acquisition of real estate by persons abroad — the Lex Koller — makes the purchase by a “person abroad” subject to authorisation. Since Brexit, a UK national falls under third-country status: without a Swiss residence permit or domicile, they fall into this category. However, holding a valid residence permit, they may acquire, without authorisation, the property intended as their main residence, as a Swiss resident would.
The correct sequence is therefore: residence permit, domicile, then acquisition. Signing a preliminary sale agreement before having the first amounts to committing to a property one is not yet entitled to buy — and making the transaction dependent on an authorisation that, for a main residence, would never have been necessary had the order been respected. Our complete map of the Lex Koller sets out each specific case.
What these buyers are looking for — and why the portals do not show it
A family leaving prime central London seeks in Geneva what they had: space, a garden, proximity to international schools, and an address that holds its standing. On the Left Bank, this points to a very limited number of properties — and this segment is not marketed through public listings.
This is not a matter of positioning: when only around a hundred people worldwide can afford to buy a given property, a listing does not serve to find them — it serves to inform the entire neighbourhood that the owner is selling. These properties therefore circulate among buyers who are already identified. Describing a confidential search is, in practice, the only way to gain access — and what discretion actually protects deserves to be understood beforehand.
A second reality to factor in: the neighbourhood determines the school. In Geneva, the assigned state school depends on domicile, and international schools are not evenly distributed across the canton. The choice of municipality therefore comes before the choice of house, not the other way round. Our guide to settling in Geneva and its English version for international families cover this point in detail.
A realistic timeline
Allow for the time needed for the cantonal tax file, then the residence permit, then the transaction itself — one to two months between the agreement and the notarial deed, longer if Swiss financing is required, as a Swiss bank reviews a foreign file methodically.
Hence the advice that costs nothing and saves the most time: start by defining the actual budget and the search scope while the administrative steps run their course, rather than discovering the Geneva market at the moment when everything needs to move quickly. A valuation of a property you already own, or an initial conversation about what you are looking for, can take place well before the move.