The Swiss lump-sum tax is very attractive. But Spain will ask you to prove you really live there.
Switzerland offers foreigners with no gainful activity in the country the lump-sum taxation (taxation based on expenditure): you are taxed on your standard of living, not on your worldwide income. But if you move from Spain, the Spanish Tax Agency can require you to prove that you really spent more than 183 days outside Spain. And the Swiss certificate alone is not enough.
GeoNotary produces that proof: a continuous, automatic expert record of your physical presence, with court validity.
Swiss tax facts (lump-sum)
| System | Lump-sum / expenditure-based taxation |
| Minimum federal tax base (2025) | CHF 434,700 |
| Condition | foreigner with no gainful activity in Switzerland |
| First residence or after | 10 years outside Switzerland |
| Wealth / inheritance | depends on canton |
| Residence threshold | domicile or effective stay |
Indicative figures as of 2026. The lump-sum regime varies by canton (some raise the minimums); consult an adviser before making decisions.
The real risk: a Spanish tax inspection
Spain's Tax Agency applies the tests in article 9 of the Personal Income Tax Act (Law 35/2006), independent of each other — meeting just one is enough:
- 1
Permanence > 183 days: your sporadic absences count as days in Spain unless you prove tax residence in another country with a certificate valid under the tax treaty.
- 2
Centre of economic interests: if your business, income or main assets remain in Spain.
- 3
Family nucleus: if your non-separated spouse and minor children reside in Spain.
The lump-sum regime requires not carrying on any gainful activity in Switzerland and residing there effectively. The Spanish debt becomes time-barred after 4 years and the move may trigger the exit tax (art. 95 bis of the Income Tax Act). An unfavourable reassessment with high income easily exceeds €300,000.
Why traditional evidence isn't enough
- Flight tickets: prove the purchase of the trip, not that you boarded.
- Utility bills: prove consumption, not the holder's personal presence.
- Card statements: prove use, not that you used it in person.
- Lump-sum ruling and permit: party-issued documents; the tax authority requires proof of effective presence.
- Google Maps Timeline: rejected by the tax authority because it is editable by the user.
How GeoNotary solves it
- Continuous, automatic location record: covers all 365 days, with no gaps in the chain of custody.
- Biomechanical verification of the carrier: confirms it was you carrying the device.
- Public blockchain sealing + eIDAS timestamp: an unalterable, verifiable record.
- Expert report: admissible before the tax authority, the Economic-Administrative Tribunals and the administrative courts.
Unlike daily-selfie check-in apps, GeoNotary doesn't rely on you remembering to register each day, nor does it leave the days you forget without proof: it records continuously and silently, and certifies who was carrying the device — not just that a phone was somewhere.
Frequently asked questions
Start proving your residence in Switzerland today
The proof is preventive: the sooner you install it, the stronger your defence.
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