US Citizen Buying Property in Switzerland

A US citizen buying property in Switzerland faces the same Swiss rules as any other foreign buyer, plus a second layer that only Americans carry: the United States taxes its citizens wherever they live. In practice, that means four things to settle before you sign anything in Gstaad. Your Lex Koller position, which depends on where you live and not on your passport. A Swiss bank willing to work with a US person. The US tax treatment of the purchase, the mortgage and the eventual sale, all measured in dollars. And an estate plan that works under both systems.

We work with American buyers in the Saanenland regularly, and the Swiss side is rarely what slows them down. It is the US side, discovered late.

General information only. Cross-border tax for US persons is specialist work. Before you buy, speak to a US tax advisor who knows Switzerland and to a Swiss notary.

The Swiss Side: Lex Koller Applies to Residence, Not Nationality

Switzerland's Federal Act on the Acquisition of Real Estate by Persons Abroad, known as Lex Koller, does not treat Americans differently from Britons, Brazilians or Singaporeans. What matters is your residence status.

Your situation	Can you buy in Gstaad?
US citizen living outside Switzerland	Holiday home only, with cantonal authorisation, within the quota and size limits
US citizen living in Switzerland with a B permit	A main residence you occupy yourself; no holiday home
US citizen with a Swiss C permit	Without Lex Koller restriction
US citizen who also holds Swiss or EU/EFTA citizenship and lives in Switzerland	Without Lex Koller restriction

For a non-resident, the holiday-home route is the relevant one. Saanen, the municipality that includes Gstaad, is a recognised tourist location with a small annual allocation from Canton Bern's quota, and authorised purchases are usually capped at around 200 m² of net living space. Our guide to Lex Koller covers the authorisation, the quota and the exceptions in detail.

Two points catch Americans in particular.

Dual citizens should check their second passport. Many American buyers also hold an EU passport through a parent or grandparent. That second citizenship only helps if you actually live in Switzerland. A non-resident Irish-American is still a person abroad for a Gstaad holiday home.

US structures often do not fit. Buying through a US LLC, a revocable living trust or a family limited partnership is standard estate planning at home. In Switzerland, a company controlled by a person abroad is itself a person abroad, and trusts raise their own questions with the notary and the land register. We explain the Swiss position in buying through a company or trust. The short version: most non-resident Americans end up holding the chalet in their own name, and solve the planning questions differently.

Banking: The FATCA Question

Since the Foreign Account Tax Compliance Act came into force, Swiss banks have had to identify US persons and report their accounts. Some banks decided that serving Americans was not worth the compliance cost. Others built dedicated desks for them.

For a property buyer, this matters at three moments.

The deposit and completion funds. The notary needs funds to arrive from an identifiable source. You will need a Swiss or international bank willing to open an account for you.
The mortgage. A US person narrows the list of Swiss lenders. In our experience, the realistic options are private banks that already manage, or will manage, part of your wealth.
Running costs. A local CHF account for the caretaker, utilities and Saanen's tax bills is practically essential.

Switzerland and the United States signed a new agreement in June 2024 to move from the current FATCA model to automatic two-way exchange of account data, with entry into force planned for 1 January 2027, subject to Swiss domestic legislation. For a compliant US taxpayer, this changes little. It does mean that the Swiss account you open for the chalet is fully visible to the IRS, which is exactly as it should be.

Mortgage terms

Non-resident buyers generally borrow less against Swiss property than residents do. Banks lend on their own valuation, which is often below the purchase price in Gstaad, and they apply a stress test at a notional rate well above today's market rates. Our guide to Swiss mortgages for foreign buyers sets out typical loan-to-value ranges. For Americans, add the narrower choice of lender, and allow more time.

The US Side: Tax on a Swiss Chalet, Measured in Dollars

This is where the surprises live. The principles below are general. Your own position depends on your residence, your other income and how you use the property.

Owning a holiday home you do not rent out

Holding Swiss real estate directly, in your own name, is not in itself reported on the FBAR or on Form 8938, because real estate is not a financial account or a specified foreign financial asset. The Swiss bank accounts that pay for it are. If you hold the property through a foreign entity, the reporting picture changes significantly, often with forms such as 5471 or 8858.

Swiss wealth tax and Canton Bern's property taxes are generally not creditable against US income tax, because they are not taxes on income.

Renting it out

Rental income from a chalet is taxable in the US as well as in Switzerland. Swiss income tax on that rent can generally be credited against your US liability under the foreign tax credit rules and the Switzerland–US income tax treaty. Depreciation rules for foreign residential property differ from domestic ones. If you plan to let the chalet in winter, read the legal side of renting a chalet in Gstaad and ask your US advisor to model the outcome before you buy.

Selling

When you sell, the US measures your gain in dollars: the dollar value of the sale price minus the dollar value of what you paid, each converted at the rate on the relevant date. Two consequences follow.

Currency can create a gain. If the franc strengthens against the dollar while you own the chalet, you can have a US taxable gain on a property that sold for exactly what you paid in francs.
Swiss tax helps, partly. Canton Bern's property gains tax is a tax on the same gain and can generally be credited. Because Bern's rate falls with the holding period and the US rate does not, long holds often leave a residual US liability.

The US exclusion of up to USD 250,000 (USD 500,000 for couples) on a home sale only applies to a principal residence you lived in for two of the last five years. A holiday chalet rarely qualifies.

The mortgage currency trap

This one deserves its own paragraph. If you borrow in Swiss francs and the franc weakens against the dollar before you repay, the dollar value of the debt you repay is lower than the dollar value you borrowed. Under US rules on foreign currency transactions, that difference can be taxable income to you, even though nothing happened in francs. If the franc strengthens instead, the corresponding loss on a personal-use property is generally not deductible. Ask your advisor about this before you choose between a CHF mortgage and paying cash. Our article on currency risk in Swiss property covers the wider FX question.

Estate Planning: Two Systems, One Treaty

The US position

US citizens are subject to federal estate tax on their worldwide estate, including a chalet in Gstaad. For 2026 the federal exemption is USD 15 million per individual, following the 2025 legislation that made the higher exemption permanent and indexed it to inflation. Many Gstaad buyers sit above that figure, so planning matters.

The Swiss position

Swiss real estate is subject to inheritance tax in the canton where it is located, whatever the owner's residence. Canton Bern exempts spouses and direct descendants, so for the most common family scenarios no Bern inheritance tax is due on the chalet. Other heirs pay at rates that depend on the relationship. Swiss succession law also has compulsory shares for certain heirs, although a foreign national living abroad can usually have their succession governed by the law of their nationality. Our guide to inheritance law and Swiss property explains the compulsory shares and the choice of law.

The 1951 treaty

Switzerland and the United States have an estate and inheritance tax treaty dated 9 July 1951, in force since 1952. It is old, and it does not eliminate every case of double taxation, but it provides credits and allocates taxing rights. Real estate stays taxable where it is situated, so Bern keeps its right to tax the chalet, and the US gives a credit for Swiss inheritance tax paid on it. For a US citizen whose heirs are a spouse or children, the practical result is often that Bern charges nothing and the US estate tax applies in the usual way.

Where the treaty gets complicated is with US citizens resident in Switzerland, or with heirs who are not spouses or children. That is a conversation for a specialist on both sides.

What About Lump-Sum Taxation?

Some Americans ask whether moving to Gstaad under Swiss lump-sum taxation would solve the tax picture. It changes the Swiss side, and it would also open the door to buying without a Lex Koller authorisation once you are resident. It does not change the US side at all: the US continues to tax a citizen's worldwide income wherever they live. Lump-sum taxation can still be attractive for the right family, but it is not an exit from US tax. Renouncing citizenship is a separate and very serious decision with its own exit tax rules.

A Practical Sequence for American Buyers

Confirm your Lex Koller status with a Swiss notary, including any second citizenship and any plan to become resident.
Open the banking relationship early. A private bank that will also consider the mortgage saves weeks.
Brief your US advisor before the offer, not after. Ask specifically about the dollar basis, the mortgage currency and rental plans.
Decide how you will hold title. Usually in your own name, sometimes jointly with a spouse, rarely through a structure.
Budget the Swiss purchase costs. Canton Bern's transfer tax is 1.8 percent of the price, plus notary and land register fees. Our guide to notary costs in Switzerland covers the rest.
Update your estate plan so that your will, and any US trust, addresses the Swiss property explicitly.

Frequently Asked Questions

Can a US citizen buy a chalet in Gstaad?

Yes. Swiss restrictions depend on residence, not nationality. A US citizen living outside Switzerland needs a Lex Koller authorisation to buy a holiday home in Gstaad, within the cantonal quota and the usual size limits. A US citizen with a Swiss C permit can buy without restriction, and one living in Switzerland on a B permit can buy a home they occupy as their main residence.

Will a Swiss bank give a mortgage to an American?

Some will, but fewer than for other nationalities, because US persons bring FATCA reporting obligations. Private banks that already manage assets for the client are the most likely lenders. Expect higher equity requirements than a Swiss resident would face.

Do I pay US tax when I sell a Swiss chalet?

Usually yes. The US taxes its citizens on worldwide gains, measured in US dollars. Swiss property gains tax paid in Canton Bern can generally be credited against the US tax on the same gain, but currency movements can create a US gain even when there is no gain in Swiss francs.

Is there an estate tax treaty between Switzerland and the United States?

Yes. The 1951 treaty between Switzerland and the United States on estate and inheritance taxes is still in force. It allocates taxing rights and provides credits, although it does not remove every case of double taxation. Swiss real estate remains taxable by the canton where it is located.

If you are an American considering Gstaad, we are happy to talk through which properties can realistically be bought under your status, and to introduce you to notaries and cross-border tax advisors who work with US clients. Get in touch.

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For a confidential conversation about your search or sale, contact The Gstaad Collection.