Background
The Voravut-Stein family is entirely fictitious. The scenario describes a bi-national Swiss-Thai founder family from the crypto sector: the founder (39, Swiss citizen, raised in Zurich) and his wife (36, Thai national from Bangkok) have lived in Phuket for several years and built a trading platform based in Singapore. Following the assumed sale of the platform to a strategic buyer, the family in this scenario holds assets in the illustrative range of CHF 60–70M, mostly in stablecoins, held in a multi-sig structure with a custody provider. The family has one child (4 years old).
In this scenario, three questions would prompt the wish to relocate:
- Regulatory environment in Thailand: possible tightening of reporting obligations for crypto assets and rising anti-money-laundering requirements
- Family-office structures in Singapore: changing requirements for family-office structures and residence permits – the existing structure would need to be reassessed
- Need for a regulated, crypto-open location: a stable European banking centre where stablecoins can be converted into CHF/EUR in a traceable way
In this scenario, the family would be looking for:
- A long-term residence in Switzerland – the options being the Lake Geneva region (Lavaux/Lutry, Canton of Vaud) and Lugano (Canton of Ticino)
- A FINMA-licensed bank with a crypto offering to convert stablecoins into CHF/EUR
- A compliant custody structure for the post-exit assets
- A home for the next 15–20 years with continuity of schooling for the child
Typical process in this scenario (5 phases)
Phase 1: Preliminary clarifications in Thailand, Singapore and Switzerland (months 1–2)
- Clarify the tax position in Thailand with a local tax adviser, including reporting obligations for crypto assets
- Plan the wind-down of the operating companies in Singapore with a local law firm
- Preliminary Swiss tax review with a tax adviser: as the founder is a Swiss citizen and, for married couples, both spouses must meet the requirements, lump-sum taxation would most likely not be available under current law – ordinary taxation in Vaud and Ticino would therefore be compared
- Initial talks with banks offering crypto services on custody and conversion of stablecoins
Phase 2: Banking relationship and crypto custody (months 2–4)
- Onboarding with a bank offering crypto services: review of identity and source of funds, among other things based on the documents for the platform sale – duration several weeks, depending on the bank
- Custody structure in line with the bank's requirements: multi-sig wallet, cold storage and complete documentation of the transaction history
- Conversion plan stablecoins → CHF/EUR, e.g. in several tranches over a few months, to limit liquidity risks
- Separate everyday banking relationship with a regional bank (CHF/EUR accounts)
Phase 3: Property search in Lugano (months 4–6)
- Search for suitable properties around Castagnola/Paradiso, including beyond public listings
- Viewings by the couple, with an eye on access to international schools in Lugano
- Example target property: villa with approx. 400 m² of living space, approx. 1,800 m² of land and a lake view
- Negotiation with the seller; purchase price in the illustrative range of CHF 8–10M
Phase 4: Purchase, residence and structure (months 6–8)
- Clarify the form of acquisition: as a Swiss citizen, the founder is generally not subject to the Lex Koller authorisation procedure; if the wife becomes co-owner, her situation would need to be reviewed in advance
- Determine the tax residence: primary residence in Vaud with a second home in Lugano, or vice versa – the centre of vital interests is decisive; to be clarified in advance with a tax adviser and the competent tax administration
- Option: a dedicated family-office company for crypto and real-estate assets – benefits and effort would need to be weighed with specialists
- Family relocation and registration with the municipality of residence
Phase 5: Schooling and integration (months 8–9)
- Enrolment of the child at an international school (multilingual: Italian, English, Thai at home)
- Option: provision for the child's education, e.g. via a foundation solution – structured by specialists
- Contacts with the crypto and founder scene around Zug (approx. 2 hours by train from Lugano)
- Option: charitable commitment, e.g. supporting education between Thailand and Switzerland
Possible outcome in the scenario (illustrative)
Tax and regulatory aspects
- Taxation: in this scenario, the family would be taxed under the ordinary regime (income and wealth). The burden depends heavily on canton, municipality and asset structure – simplified comparisons do not replace tax or legal advice; individual review by specialists is required.
- Crypto assets: in Switzerland, cryptocurrencies and stablecoins are generally subject to wealth tax; whether their management counts as private or commercial must be assessed individually.
- Regulated custody: a FINMA-licensed bank can handle custody and conversion in a traceable way – requirements and costs differ from one institution to another.
- Conversion risk: a staggered conversion plan can limit liquidity and de-pegging risks of stablecoins.
Lugano as a location
- Lugano as a place to live and work, with an Italian-speaking environment close to northern Italy
- Separate banking relationships: everyday accounts with a regional bank, crypto custody with a specialised bank
- Rail connections to Zug and Zurich for meetings within the founder community
Family and integration
- In this scenario, the child would attend an international school (Italian in daily life, English and Thai at home)
- A charitable commitment could strengthen the connection between Thailand and Switzerland
- Travel to Thailand via Zurich Airport – the link to the family in Bangkok would be maintained
What the scenario shows
1. Citizenship shapes the tax options. Lump-sum taxation is only available to persons without Swiss citizenship who do not pursue gainful employment in Switzerland; for married couples, both spouses must meet the requirements. Bi-national families should clarify this question early with specialists.
2. The banking relationship needs lead time. Banks offering crypto services examine the source of funds and transaction history in detail. Clean documentation of the exit makes onboarding easier.
3. Two regions, one centre of life. Combining the Lake Geneva region and Lugano can be attractive, but for tax purposes the centre of vital interests is what counts. The choice of primary residence should be made with specialists.
4. Align conversion and property purchase. A staggered conversion plan stablecoins → CHF/EUR can be coordinated with the payment schedule of the property purchase – in consultation with the bank and the notary.