Is there a double taxation treaty between Switzerland and the UAE?

Yes. The treaty has been in force since 2012 and follows the OECD Model Convention. Unlike Germany, which let its UAE treaty lapse at the end of 2021, the Swiss treaty is active. Among other things it determines in which of the two states a person is considered resident when both raise a claim.

Does Switzerland have an exit tax like Germany or Austria?

No comparable one. Private capital gains are generally tax-free in Switzerland, so there is no equivalent to Germany's § 6 AStG or Austria's § 27 (6) EStG taxing shareholdings on departure. That is the material advantage of the Swiss starting position. Other points (indirect partial liquidation, transposition, pension assets) still need checking case by case.

What happens to pension fund and pillar 3a assets when moving to Dubai?

On leaving Switzerland, pillar 3a assets can be withdrawn in cash; whether a vested benefit from the occupational pension fund can be paid out in full depends on the nature of the departure and the type of benefit. After deregistration the payout is taxed at source at the seat of the pension institution. Whether that withholding tax can be reclaimed depends on the treaty and generally requires a certificate of residence from the new country, for the UAE, something to clarify case by case.

What counts as transferring tax residence?

Deregistering with the municipality alone is not enough. What matters are the actual circumstances: where the family lives, where you genuinely live and work, where the centre of vital interests sits. If both states raise a claim, the treaty's tie-breaker rule decides, in this order: permanent home, centre of vital interests, habitual abode, nationality.

Insights

Switzerland and the UAE in 2026: Relocation, Treaty and Pension Assets

Switzerland has maintained an active double taxation treaty with the United Arab Emirates since 2012 and levies no exit tax on private capital gains. The starting position for Swiss founders is therefore better than for German ones. The critical points sit elsewhere: in the actual transfer of residence, and in pension assets.

Last updated: July 27, 2026

The treaty: in force since 2012

Switzerland and the United Arab Emirates have maintained a double taxation treaty modelled on the OECD Convention since 2012. For Swiss founders this is the decisive difference from the German position: Germany let its UAE treaty lapse at the end of 2021 and has treated the Emirates without treaty protection ever since. Swiss taxpayers have that protection.

In practice that means two things. First, the treaty settles residence where both states claim a person. Second, Switzerland relieves double taxation under Article 22 principally through the exemption method, subject to progression: exempted income may still be taken into account when determining the applicable rate.

No exit tax on shareholdings

The biggest difference from Germany and Austria: Switzerland has no exit tax on shares in corporations. Private capital gains are generally tax-free in Switzerland, so there is no counterpart to § 6 AStG (Germany) or § 27 (6) EStG (Austria). Holding a valuable participation does not trigger a deemed disposal on departure.

Still worth checking

Tax-free does not mean care-free. For privately held participations, constellations such as indirect partial liquidation or transposition can produce taxable investment income, independently of any departure. Anyone restructuring or selling their Swiss company alongside the move should have that calculated by a Swiss tax adviser beforehand.

Transferring residence: deregistration is only the start

Deregistering with the municipality is a formality, not tax evidence. What counts are the actual circumstances: where the family lives, where you genuinely reside and work, where contracts, vehicles and insurance policies run. Deregistering while keeping the flat, the family and the mandates in Switzerland risks continued treatment as a Swiss resident.

Where both states claim residence, the treaty's tie-breaker rule applies, tested in this order: permanent home, centre of vital interests, habitual abode, nationality. A real home in Dubai, a genuine centre of life there and documented days present are therefore not paperwork. They are the substance of the matter.

Pension fund and pillar 3a: the single most expensive item

On leaving Switzerland for good, pillar 3a assets can be withdrawn in cash. Whether a vested benefit from the occupational pension fund can be paid out in full depends on the nature of the departure and on whether mandatory or extra-mandatory portions are involved.

For tax purposes: after deregistration, pension benefits remain subject to limited tax liability on the basis of economic affiliation. The payout is taxed at source at the seat of the pension institution, and cantons differ considerably here. Whether that withholding tax can then be reclaimed depends on the treaty and generally requires a certificate of residence from the new country. For the UAE this needs clarifying case by case before the payout, not after.

The sequence that works

Calculate first, deregister second: go through pension assets, participations and ongoing mandates with a Swiss tax adviser before fixing a date.
Set up the UAE structure: company, licence, bank account and visa, so the new residence can be evidenced at all.
Actually move the centre of life: home, days present, contracts, insurance. Collect the evidence as you go rather than reconstructing it later.
Only then draw pension assets, once residence and the withholding question are settled.

Status and scope

This article reflects the position as of July 2026 and does not replace an assessment of your specific case. Swiss tax law and the treatment of pension assets belong with your Swiss tax adviser; Firstgate is responsible for the UAE side (company, licence, substance, visa and ongoing compliance) and supplies the evidence the residence question requires.

Frequently asked questions

Is there a double taxation treaty between Switzerland and the UAE?: Yes. The treaty has been in force since 2012 and follows the OECD Model Convention. Unlike Germany, which let its UAE treaty lapse at the end of 2021, the Swiss treaty is active. Among other things it determines in which of the two states a person is considered resident when both raise a claim.
Does Switzerland have an exit tax like Germany or Austria?: No comparable one. Private capital gains are generally tax-free in Switzerland, so there is no equivalent to Germany's § 6 AStG or Austria's § 27 (6) EStG taxing shareholdings on departure. That is the material advantage of the Swiss starting position. Other points (indirect partial liquidation, transposition, pension assets) still need checking case by case.
What happens to pension fund and pillar 3a assets when moving to Dubai?: On leaving Switzerland, pillar 3a assets can be withdrawn in cash; whether a vested benefit from the occupational pension fund can be paid out in full depends on the nature of the departure and the type of benefit. After deregistration the payout is taxed at source at the seat of the pension institution. Whether that withholding tax can be reclaimed depends on the treaty and generally requires a certificate of residence from the new country, for the UAE, something to clarify case by case.
What counts as transferring tax residence?: Deregistering with the municipality alone is not enough. What matters are the actual circumstances: where the family lives, where you genuinely live and work, where the centre of vital interests sits. If both states raise a claim, the treaty's tie-breaker rule decides, in this order: permanent home, centre of vital interests, habitual abode, nationality.