Initial situation
The Lefèvre family (anonymised) belongs to the third generation of a Parisian private-banking dynasty. The heiress (44) took over the family's affairs following the death of her father in early 2025 — consolidated assets of ~CHF 95M (securities, Parisian real estate in the 7th arrondissement, art collection). Her husband (47) is a partner at an international law firm. Three children (10, 14, 17), all enrolled at the École Active Bilingue in Paris.
Trigger for the Beherzig mandate: the 2026 French income-tax (IRPP) reform (a progressive tightening of the top brackets combined with the continued wealth tax on real estate, IFI) coupled with a mobility clause imposed by the paternal will requiring the transfer of the tax domicile out of France in order to release the inheritance. The Lefèvre family were seeking:
- Lump-sum taxation in the Canton of Geneva — approved for residence in a premium urban zone
- A family villa in Cologny for multi-generational stability
- An educational track at Le Rosey + Aiglon for all three children (rotation 2026-2030)
- IFI optimisation / transfer of the financial assets into a Swiss jurisdiction
Beherzig solution: 5-phase mandate
Phase 1: Pre-migration Paris (Months 1-2)
- Pre-departure tax audit with Bredin Prat (Paris firm, Exit Tax under art. 167 bis CGI)
- Lump-sum taxation study for the Canton of Geneva via Schellenberg Wittmer (Geneva) — taxable base CHF 480,000
- Pre-validation of the will's mobility clause with the family's Parisian notary
- Framing of the partial exit of the IFI-relevant assets towards a Swiss/Liechtenstein structure
Phase 2: Cologny property sourcing (Months 2-4)
- Beherzig Confidential Pool: 4 candidates in Cologny / Vésenaz / Anières identified under NDA
- 2 private viewings with the Lefèvre couple (Geneva weekends disguised as Le Rosey visits)
- Choice of the Cologny-Plateau villa (1962, renovated 2018, 680 m² living space, 3,800 m² grounds with lake view)
- Off-market negotiation via the vendor's family office (fourth-generation Franco-Swiss industrial heritage)
- Closing price: CHF 28M (BOMPI +16% vs public benchmark Cologny-Plateau Q1 2026)
Phase 3: Closing + Lex Koller (Months 4-5)
- Acquisition by the Lefèvre spouses in full ownership (Lex Koller GE not required — lump-sum taxation + primary residence)
- Lump-sum tax ruling for the Canton of Geneva signed (CHF 480,000 annual taxable base)
- French Exit Tax settlement: spread over 5 years with a bank guarantee (art. 167 bis CGI)
- Effective relocation Paris → Cologny (March 2026)
Phase 4: Education track Le Rosey + Aiglon (Months 5-6)
- Enrolment of the eldest child (17) at Le Rosey Rolle — winter campus in Gstaad included (start September 2026)
- Enrolment of the middle child (14) at Aiglon College Villars — German-bilingual track
- Youngest child (10) at the International School of Geneva (La Châtaigneraie Campus) — close to Cologny
- Setting up a sports track (equestrianism in Geneva + winter skiing in Verbier)
Phase 5: IFI optimisation + family-office setup (Months 6-7)
- Gradual transfer of the financial assets to Geneva private banks (Pictet, Lombard Odier)
- Establishment of a Liechtenstein foundation (Vaduz) for the family's art-collection portfolio (CHF 12M)
- Strategic retention of a Parisian pied-à-terre (75007) as a passive rental — reduced IFI
- Geneva multi-family-office partner engaged (Reyl & Cie) for consolidated management
Outcome 8 months post-closing (Q3 2026)
Tax optimisation
- France, pre-migration: ~CHF 2.8M IRPP + IFI combined per year
- Switzerland, Geneva lump-sum taxation post-2026: ~CHF 220,000/year (base CHF 480,000 × 46% federal/cantonal/communal)
- Saving: ~CHF 2.58M per year (-92% compared with the French situation)
- IFI effect: Complete disappearance of the IFI on the financial assets (~CHF 70M released)
Education track Le Rosey + Aiglon
- Three children integrated into the Swiss educational elite: Le Rosey (17), Aiglon (14), Châtaigneraie (10)
- Multi-generational network open to all three children (Le Rosey alumni, CHF 95M+ wealth tier)
- Retention of French as the principal language + German-language immersion at Aiglon
Family stability + heritage
- The Cologny villa becomes the new family anchor — close to Geneva (15 min) and the airport (20 min)
- Monthly return to Paris made easy (TGV Lyria, 3h15 Geneva-Paris) for banking-family-office activities
- The Lefèvre Heritage Foundation (CHF 1.5M endowment) funds Le Rosey scholarships for students from French-speaking Switzerland
Key learnings for French private-banking clientele
1. The 2026 French IRPP reform is accelerating departures. Heirs of Parisian private banking are facing a structural tightening. Swiss lump-sum taxation remains the most effective tool for preserving multi-generational capital — provided the migration is anticipated 6-9 months in advance.
2. The testamentary mobility clause is an underestimated trigger. More and more French patriarchs are contractually imposing the transfer out of France as a condition of the succession. Beherzig observes this trend in 30% of Cluster B mandates.
3. Cologny remains the premium micro-market of French-speaking Switzerland. Plateau-Cologny, with its lake view and proximity to Le Rosey/Châtaigneraie, reaches CHF 25-35M for benchmark villas. The off-market route via the vendor's family office avoids media pressure.
4. The Le Rosey + Aiglon education track is a multi-generational investment. Beyond academic quality, the alumni network (notably international UHNWIs from Cluster A) constitutes social capital that can be passed on to the next generation. Beherzig systematically coordinates with both institutions.