Can a non-Swiss tax resident open an account with a Swiss bank?

Yes. Swiss banks and independent portfolio managers routinely serve non-resident clients, subject to KYC and source-of-wealth checks, the bank's country-acceptance policy, and minimum relationship sizes that typically start between CHF 500,000 and CHF 1,000,000.

Is a Swiss account still confidential for a foreign resident?

No. Switzerland applies the OECD Common Reporting Standard. Account balances and income of non-resident clients are reported annually to their country of tax residence. A Swiss relationship is a jurisdictional and quality choice, not a way to avoid disclosure.

Do I pay Swiss tax on a portfolio held in Switzerland if I live abroad?

Generally a non-resident is not subject to Swiss income or wealth tax on a securities portfolio held in Switzerland. Swiss-source dividends and interest suffer 35% Swiss withholding tax, which is usually reclaimable in whole or in part under the applicable double-tax treaty. Taxation of the portfolio happens in the country of residence.

Should I choose a bank or an independent portfolio manager?

An independent portfolio manager selects the strategy and manages the mandate while assets stay in the client's name at a custodian bank. This separates management from custody and usually gives a more transparent fee structure than an all-in-one bank relationship.

Investing with a Swiss Intermediary as a Non-Resident

Who this guide is for

You live and pay tax outside Switzerland — in Italy, Germany, France, the UK, the Gulf, Latin America or elsewhere — and you are considering holding part of your wealth with a Swiss bank or a Swiss independent portfolio manager. This guide explains how such a relationship works in practice, what is legal and expected, and what to verify before signing.

It is general information, not tax or legal advice: the decisive rules are always those of your country of residence, and they should be checked with a local adviser.

What a "Swiss intermediary" actually means

Three different roles are often confused. Separating them is the single most useful thing a new client can do.

The custodian bank holds your assets. The account is in your name; the bank safekeeps the securities, executes trades and produces statements.
The portfolio manager decides or recommends what to buy and sell. This can be a department inside the bank, or an independent manager supervised by FINMA through a recognised supervisory organisation.
The adviser network — tax adviser, notary, lawyer — handles the framework in your own country.

With an independent manager, management and custody are separated: the manager never holds your money, and you can change manager without moving the assets.

Onboarding: what a non-resident should expect

Swiss onboarding is thorough, and being non-resident makes it more so. A typical file includes:

Passport and proof of your residential address.
A self-certification of tax residence and tax identification number (for CRS purposes), plus a W-8BEN if there is any US exposure.
Source of wealth and source of funds: how the capital was built (company sale, salary and savings, inheritance, real-estate disposal) with supporting documents.
Confirmation that the assets are declared in your country of residence.

Each bank also applies a country-acceptance policy: some nationalities and residences require additional review, and some are not accepted at all. Minimums for a managed relationship typically start between CHF 500,000 and CHF 1,000,000, though independent managers are often more flexible.

Transparency: CRS and automatic exchange of information

Switzerland participates in the OECD Common Reporting Standard. Every year, the balance and the income of a non-resident's account are reported to the Swiss authorities and forwarded to the tax authority of the client's country of residence.

The practical consequence: a Swiss relationship is chosen for stability, currency access, institutional quality and investment expertise — never for opacity. Everything should be declared in your home country, and a good intermediary will insist on it.

Swiss withholding tax and treaty reclaims

Swiss-source dividends and certain interest are subject to a 35% federal withholding tax (impôt anticipé). A non-resident can normally reclaim part or all of it under the double-tax treaty between Switzerland and their country of residence — the residual rate is often 15%, and sometimes 0% for pension vehicles.

The reclaim is filed with the Swiss Federal Tax Administration, usually with a residence certificate from your local tax office.
Holding non-Swiss securities in a Swiss custody account does not create Swiss withholding tax; foreign issuers apply their own rules (for example 15% on US dividends with a valid W-8BEN).
A portfolio designed for a non-resident should take these frictions into account before deciding where and in what form to hold an asset.

Also worth knowing: Switzerland levies a small stamp duty on securities transactions handled by a Swiss dealer, and there is no Swiss capital-gains tax for private investors.

Taxation in your country of residence

This is where the real tax bill sits. Common points to raise with your local adviser before opening an account:

Whether foreign accounts must be declared on a dedicated form (for example the Italian quadro RW and IVAFE, the French formulaire 3916, or an equivalent).
How your country treats accumulating funds, ETFs domiciled in Ireland or Luxembourg, and structured products — the treatment can differ sharply from directly held bonds and shares.
Whether a discretionary mandate changes anything in your local reporting, and who produces the tax statement you will need.
Currency: the reporting currency of your tax return versus the reference currency of the portfolio.

Most Swiss custodians can issue a tax reporting package tailored to selected countries. Ask whether yours is covered, and at what cost, before you open the relationship.

Choosing the mandate: advisory or discretionary

In an advisory mandate you approve each decision. It suits investors who want to stay involved — but for a client in a different time zone, chasing approvals can slow execution.

In a discretionary mandate the manager invests within an agreed written strategy: objectives, risk profile, reference currency, constraints. For most non-resident clients this is the more practical structure, precisely because it does not depend on being reachable.

Costs: what to ask for in writing

Management fee, as a percentage of assets under management.
Custody and account-maintenance fees charged by the bank.
Transaction, FX conversion and stamp-duty costs.
Embedded fund fees, and whether any retrocessions are received and rebated to you.
Any fee for country-specific tax reporting or treaty reclaim handling.

The number that matters is the all-in annual cost as a percentage of assets. Ask for it as a single figure.

A short due-diligence checklist

Is the manager supervised by FINMA or a recognised supervisory organisation?
Which custodian bank will hold the assets, and in whose name?
Does the bank accept clients resident in my country?
Which tax reporting package is available for my jurisdiction?
Who handles the 35% withholding tax reclaim — me, or the bank?
What is the all-in annual cost, and can I exit without penalty?
Who is my direct contact, in which languages, and who covers absences?

How I work with non-resident clients

As a Portfolio Manager at Genève Invest in Geneva, I manage advisory and discretionary mandates for private clients based both inside and outside Switzerland. The approach is fundamentals-driven, long-term and conservative, built around directly held bonds and equities so that positions, income and costs stay legible for the client and for their local tax adviser. I work alongside your own tax counsel rather than replacing them.