Visa holders · From Switzerland
You can cash out your whole pillar 2 when moving to the US from Switzerland: taxes on the cash turn on your US residency starting date.
Switzerland withholds source tax from a pillar 2 payout (your workplace pension). Part is federal, and the canton where the fund has its seat sets the rest. The US taxes a pillar 2 payout you receive as a US resident, less your investment in the plan. You can then reclaim the Swiss tax on a private-law fund’s payout, with proof that the IRS knows of it. Only US citizens get that refund on a payout from a public-law fund, such as a canton’s. If you take pillar 2 before your US residency starts, the cash is generally free of US tax, but the Swiss tax stays.
Updated · Sources
Swiss tax you can claim back
- 3 years
- is how long a US resident has to reclaim Swiss source tax on a private pillar 2 or 3a lump sum.
- Dec. 31, 2029
- is the last day to reclaim Swiss withholding tax on a dividend that fell due in 2026.
- 15%
- is what Switzerland keeps from your Swiss dividends once you claim the refund as a US resident.
Each refund lapses once its deadline passes.
What should you check before you leave Switzerland?
Your US residency starting date
Your US residency starts on your first day here in the year you meet the substantial presence test, or sooner with a green card. Up to 10 days of short visits can be left out, if your tax home and closer ties stayed in Switzerland. Swiss income you receive from your US residency starting date is US-taxable, even if you earned it before the move.
Your last Swiss tax year
Swiss federal tax on your last year falls due as soon as you make arrangements to leave for good. The canton can also demand security, a guarantee that you will pay. If you keep a Swiss home, you may stay domiciled there, and the treaty’s tie-breaker then decides where you are resident.
Shares and funds you hold privately
Arriving in the US does not raise your cost basis to market value. Gains built up in your Swiss years are therefore taxed if you sell as a US resident. If you sell before your US residency starts, those gains generally escape tax in both countries.
Pillar 2 you leave in Switzerland
If you leave your pillar 2 in Switzerland, tell your fund whether to hold it in a vested benefits account or policy. Without instructions, it goes to the substitute institution, Switzerland’s fallback pension fund, six months to two years after you leave the fund. The IRS has not said how it taxes growth in pillar 2 or 3a, and no treaty article defers that tax.
A pillar 3a account
You can close a 3a account when you leave Switzerland for good, or keep it. If you withdraw it while you still live there, Switzerland taxes it separately at a reduced federal rate, and that tax is final. After you leave, a withdrawal bears pillar 2’s source tax, which is refunded only if you are a US resident when paid.
A spouse or registered partner must agree in writing before you take pillar 2 or 3a in cash.
On CHF 10,000 of Swiss dividends, a refund claim cuts Switzerland’s tax from CHF 3,500 to CHF 1,500.
Swiss payers withhold the full 35% even from a US resident. You reclaim the part above the treaty rate from the Swiss Federal Tax Administration (ESTV), on Form 82 I or online.
Dividends, no claim filed
CHF 3,500
Switzerland keeps the whole 35%, and the US still credits no more than the treaty rate.
Dividends, refund claimed
CHF 1,500
The ESTV repays CHF 2,000, and the CHF 1,500 left is the tax you can credit in the US.
Bank interest, refund claimed
CHF 0
All CHF 3,500 comes back, because the treaty leaves interest to the US alone.
The Withholding Tax Act, in Article 13, sets Switzerland’s tax on dividends and interest at 35%. The ordinance to the treaty refunds 20% of a dividend’s gross amount and all 35% of interest. That leaves the treaty rate on dividends (Article 10(2)(b)) and nothing on interest (Article 11(1)). Treas. Reg. § 1.901-2(e)(5) treats tax you could reclaim as not paid. US tax on the income is not shown.
Which Swiss income does the US-Swiss tax treaty still leave to Switzerland?
For a US resident, the treaty mainly limits what Switzerland may tax. Its saving clause, Article 1(2), binds only the US. It lets the US tax its residents and citizens as if the treaty did not exist, with listed exceptions.
| Switzerland | US | |
|---|---|---|
| Pension from a private Swiss fund or 3a | Not taxed Lump sums: withheld, then refundable | Taxed |
| Pension for Swiss public service | Taxed Article 19(2) | Exempt on a visa Taxed with a green card or US citizenship |
| AHV old-age pension | Not taxed When paid abroad | Taxed as an annuity |
| Gains on Swiss shares and funds | Not taxed Unless the company mostly owns Swiss land | Taxed |
| A home or land you keep in Switzerland | Taxed Plus wealth tax on it | Rent and sale gains taxed Credit for Swiss income tax, not wealth tax |
A Swiss public-service pension paid to a US citizen living in the US is taxed by the US alone.
Which slips forfeit a Swiss refund or add US tax and penalties?
Expecting a refund from a public pension fund
Source tax on a lump sum from a public-law fund, such as a canton’s, is not refunded to visa or green card holders. The treaty lets Switzerland tax public-service pensions.
Leaving the refund proof until late
The canton asks for proof that the IRS knows of the payout. We found no published rule on what proof it accepts from a US resident. Ask it early, before the claim can lapse.
Keeping Swiss funds after you arrive
A Swiss contractual fund or SICAV usually counts as a passive foreign investment company (PFIC) once you are a US resident. Each one then generally needs its own Form 8621 every year, and funds held inside a 3a account may too.
Overlooking vested benefits and 3a accounts
A vested benefits or 3a account held at a Swiss bank foundation may belong on your FBAR and on Form 8938. Whether Form 3520 applies to it is unresolved.
Joining the US affiliate during a posting
A Swiss certificate of coverage can keep a posted worker in AHV and out of US Social Security. The US-Swiss social security agreement counts a US affiliate as the same employer only for workers sent from the US. If you become an employee of the US affiliate instead of your Swiss employer, you may lose that exemption.
We work out the US tax on your pillar 2 and put your Swiss accounts on the right forms.
Our CPAs prepare only your US returns once you leave Switzerland. A Swiss accountant files your final Swiss return, and we coordinate with them.
- We report a pillar 2 or 3a payout on your US return and work out your investment in the plan.
- We compare taking your pillar 2 before your US residency starts with taking it after. We then set your estimated payments for the year the cash lands.
- We put your Swiss bank, vested benefits and 3a accounts on the FBAR and Form 8938 where they belong. Every Swiss fund that needs a Form 8621 gets one. The instant quote prices each Swiss account and fund you list, and any Swiss company in which you own more than 20%.
- We credit only the Swiss tax you cannot reclaim, on Form 1116.
- Within the fee, we answer IRS and state notices about the returns we prepared, including questions on your AHV pension.
- Individual return
- from $195
- Business return
- from $495
We quote a flat fee before work starts. We do not bill hourly.
How do Swiss and US taxes differ once you make the move?
Does Switzerland have a tax treaty with the US?
Yes. Under the US-Switzerland tax treaty, a US resident reclaims 20 of the 35 percentage points Switzerland withholds from dividends, so Switzerland keeps 15%. The treaty was signed on October 2, 1996, and has applied since January 1, 1998. Interest and private pensions are taxed only where you live. The treaty’s saving clause binds only the US. A 2009 protocol, in force since September 20, 2019, lets the tax authorities exchange information that bank secrecy once shielded. A separate 1951 treaty covers estate tax.
Who has higher taxes, the US or Switzerland?
Whether the US or Switzerland taxes you more depends on your canton, your state and your income. Swiss federal income tax never takes more than 11.5% of taxable income, but cantons and communes add their own income tax. Switzerland also taxes wealth each year, and the US has no federal wealth tax. Swiss income tax you cannot reclaim can offset US tax on the same income through the foreign tax credit. In 2026, US federal income tax on $100,000 of wages is $13,170 for a single filer taking the standard deduction, before state tax. Social Security and Medicare take another 7.65%, unless a Swiss certificate of coverage keeps you in AHV.
How much is $100,000 after tax in Switzerland?
Switzerland has no single take-home figure for $100,000, because each canton and commune sets most of the income tax. The federal part is small: CHF 2,684.35 on CHF 100,000 of taxable income for a single person in 2026. A married couple owes CHF 1,816 of federal tax on the same income. These figures are for taxable income in francs, after deductions, not for a $100,000 salary. The Swiss Federal Tax Administration’s online calculator gives the total for any commune.
Does Switzerland have an exit tax?
No, there is no Swiss exit tax on private assets. Switzerland does not tax gains on private shares, funds and other movable assets, though cantons tax gains on Swiss real estate. The exceptions are business assets you take abroad, a Swiss company whose seat moves abroad, and gains from professional securities trading. Blocked employee options, which you cannot exercise or sell until a set date, are taxed when exercised after you leave. Switzerland then charges 11.5% federal plus cantonal tax, on the part earned while you worked there.
Does the US tax my AHV pension?
Yes, the US taxes your AHV pension once you live here, and Switzerland does not tax AHV paid abroad. The treaty does not treat AHV as US Social Security, so it is taxed under the annuity rules. The cap that taxes at most 85% of a US Social Security benefit does not apply. No IRS guidance says how much of it is a tax-free return of your own contributions. AHV stays off Form 8938, which leaves out foreign social security.
Sources
- US-Switzerland income tax convention (1996)
- Treasury, technical explanation of the US-Switzerland convention (1996)
- IRS, Switzerland tax treaty documents
- ESTV, country page for the United States (treaties and refund forms)
- ESTV, claim to refund of Swiss anticipatory tax
- Switzerland, SR 672.933.61, Verordnung zum schweizerisch-amerikanischen Doppelbesteuerungsabkommen (ordinance to the treaty)
- Switzerland, SR 642.11, Bundesgesetz über die direkte Bundessteuer (DBG)
- Switzerland, SR 831.42, Freizügigkeitsgesetz (FZG)
- Switzerland, SR 831.461.3, Verordnung über die steuerliche Abzugsberechtigung für Beiträge an anerkannte Vorsorgeformen (BVV 3)
- Switzerland, SR 642.21, Bundesgesetz über die Verrechnungssteuer (VStG)
- Social Security Administration, US-Switzerland social security agreement (text)
- IRS, Publication 915, Social Security and Equivalent Railroad Retirement Benefits
- 26 U.S.C. § 72, Annuities (investment in the contract)
- 26 C.F.R. § 1.901-2, Income, war profits, or excess profits tax paid or accrued
- 26 C.F.R. § 1.1298-1, Section 1298(f) annual reporting for PFIC shareholders (Form 8621)
- 31 C.F.R. § 1010.350, Reports of foreign financial accounts
- IRS, Rev. Proc. 2025-32 (2026 inflation adjustments)
Reviewed and updated September 2026. General information, not advice for your situation.