Initial situation in the scenario
In this scenario, the fictitious Lefèvre family comes from a third-generation Parisian banking family. The heiress (44) took over the management of the family wealth after her father's death – illustrative order of magnitude CHF 90–100M (securities, Parisian real estate in the 7th arrondissement, art collection). Her husband (47) is a partner at an international law firm. The three children (10, 14, 17) attend a bilingual school in Paris.
Triggers in this scenario: possible tightening of French taxation (top income-tax rates, real-estate wealth tax IFI) and a condition in the father's will linked to moving the tax residence outside France. Whether such a clause would be valid would need to be checked by a notary. In this scenario, the family is looking for:
- possible lump-sum taxation (taxation based on expenditure) in the Canton of Geneva – the requirements would need to be clarified in advance with the cantonal tax administration
- a family villa in Cologny for multi-generational stability
- suitable international schools in French-speaking Switzerland for the three children
- a reorganisation of asset management and real-estate holdings with a view to the French IFI
Typical process in this scenario (5 phases)
Phase 1: Preparation in Paris (Months 1-2)
- Departure tax analysis with a French tax firm, including review of any exit taxation (Exit Tax, art. 167 bis CGI)
- Review of lump-sum taxation in the Canton of Geneva with a tax adviser in Geneva – in the scenario with an illustrative tax base of CHF 480,000
- Important: lump-sum taxation requires, among other things, that neither spouse is gainfully employed in Switzerland – the husband's legal practice would need to be clarified in advance
- Review of the testamentary condition by the family's Parisian notary
- Initial considerations on structuring financial and real-estate assets with specialists
Phase 2: Property search in Cologny (Months 2-4)
- Search for suitable properties in Cologny, Vésenaz and Anières – also beyond public listings, where owners are open to a discreet exchange
- Discreet viewings, coordinated with the family's calendar
- Example target property: a villa on the Cologny plateau with lake view (illustrative: approx. 650–700 m² living space, around 3,500–4,000 m² of grounds)
- Negotiation with the owner side, for example the family office of an entrepreneurial family
- Price in this scenario: illustrative range CHF 25–30M, depending on location, condition and market environment
Phase 3: Acquisition + Lex Koller (Months 4-5)
- Acquisition by the spouses: for EU nationals resident in Switzerland, a primary residence generally does not require a Lex Koller permit – to be checked case by case
- Lump-sum taxation would need to be clarified in advance with the Geneva tax administration (e.g. via an advance enquiry)
- Any French exit taxation and its payment terms would need to be coordinated with the French tax adviser
- Move Paris → Cologny only once these preliminary clarifications are complete
Phase 4: School choice in French-speaking Switzerland (Months 5-6)
- Exploring admission of the eldest child (17) to a boarding school in French-speaking Switzerland (e.g. Le Rosey, Rolle)
- For the middle child (14), comparing further international boarding schools (e.g. in Villars)
- For the youngest child (10), an international day school in Geneva close to Cologny
- Admission decisions rest solely with the schools; plan for deadlines early
Phase 5: Wealth structure + family office (Months 6-7)
- Possible gradual transfer of asset management to a private bank in Geneva
- Review of a foundation or trust solution for the art collection (e.g. in Liechtenstein) with specialist advisers
- Weighing whether to keep a Paris apartment: real estate located in France may remain subject to IFI even after departure
- Optional: involving a multi-family office in Geneva for consolidated management
Possible outcome in the scenario (illustrative)
Tax considerations (simplified model calculation)
- France before departure: assumed in the model at around CHF 2.8M income tax and IFI per year
- Geneva lump-sum taxation: with an illustrative tax base of CHF 480,000 and an assumed overall rate of around 46%, this would amount to around CHF 220,000 per year
- Difference in the model: around CHF 2.5M per year – the actual burden depends on the structure and on the authorities' decision
- IFI: IFI only covers real estate; after departure, generally only real estate located in France would remain taxable
- Simplified model calculation, not tax or legal advice. An individual review by qualified professionals is required.
Schools and family
- The children could continue their schooling in French while also deepening English or German
- A villa in Cologny could become the new family base — around 15 min from Geneva and 20 min from the airport
- Paris would remain easily accessible (TGV Lyria, around 3 hours Geneva–Paris)
What the scenario shows
1. Leaving France requires lead time. Tax, inheritance and family questions are intertwined. A timeframe of 6–9 months is a typical guide, not a promise.
2. Testamentary conditions should be reviewed early. Whether and how a residence condition takes effect is a question for a notary and inheritance specialists – before any property decisions are made.
3. Cologny is a sought-after micro-market in French-speaking Switzerland. Lake-view villas on the plateau are – as an illustrative order of magnitude – in the double-digit millions. A discreet search, including beyond public listings, can help avoid public attention.
4. School choice and place of residence are linked. Anyone considering boarding schools and international schools in French-speaking Switzerland should factor admission deadlines and commuting into the property search.