Buying in Zurich vs back home: Lex Koller, gains tax and the IRS
In Zurich your permit decides what you can buy. The fees are tiny; the prices, the down payment and the tax on a quick sale are not.
The short version
- On a B permit you can buy one home to live in, without approval. On a C permit you buy like a Swiss citizen. Living in the US, you generally can't buy a Zurich home at all [1].
- A proposed tightening of Lex Koller would make non-EU buyers who live here, Americans included, need approval for a home to live in. Its consultation closed on July 15, 2026, and it isn't law [2].
- Zurich has no transfer tax. Notary and land registry fees run about 1 per mille each of the price [3][4].
- The canton's property gains tax runs from 10% to 40%, with a surcharge for a quick sale and a discount after five years [5].
- The IRS taxes your worldwide gain, in dollars, with Section 121 and the foreign tax credit to soften it [6][7].
USD conversions use the Federal Reserve H.10 rate of October 30, 2026 (CHF 0.823 per US dollar), rounded.
Can Americans buy in Zurich?
Switzerland's Lex Koller law limits property purchases by "persons abroad." For an American, it depends on your permit [1]:
| Your status | Can you buy a home in Zurich? |
|---|---|
| Living in the US | Generally no. Holiday homes only in cantons' designated resort areas, which don't include the city of Zurich |
| B permit, living in Zurich | Yes, one home at your place of residence, in your own name, lived in by you, with no part rented out |
| C permit, actually living in Switzerland | Yes, on the same terms as a Swiss citizen |
A few fine-print points from the federal guidelines [1]:
- One unit, owner-occupied. On a B permit you can't buy a second apartment for rent, and you can't rent out a room in your own.
- Moving away doesn't currently force a sale. But buying with no intention of living there can mean retroactive approval and reversal of the purchase.
- Large plots get reviewed. Land over 3,000 m² (about 32,300 sq ft) goes to the authorities.
Now the heads-up. In April 2026 the Federal Council opened consultation on a tighter Lex Koller. Third-country nationals, which includes Americans on a B permit, would need approval to buy a home to live in [2]. The consultation closed on July 15, 2026, and the Federal Office of Justice's project page showed no bill sent to Parliament as of early November 2026. It's a draft: Parliament still has to pass it, and a referendum is possible. If you're on a B permit and serious about buying, watch this closely. Our guide to Swiss permits for Americans explains the path to a C.
Getting a loan: Swiss bank or US lender?
In Zurich. Swiss mortgages are built around a large down payment: expect to put in at least a fifth of the price, with part of it in cash or savings rather than pension money, and to pass an affordability test that assumes a notional interest rate well above today's rates. Many Swiss owners never fully pay off their mortgage. Finding a bank is its own task for Americans; see why Swiss banks refuse Americans, and which don't.
Back home. Some Americans borrow against a US home or savings for the down payment. See US mortgages for Americans living abroad.
The currency trap. The IRS measures a franc mortgage in dollars. The franc has a long record of strength against the dollar, and if it strengthens while you owe it, you'll repay more dollars (a nondeductible loss on a personal home loan). If it weakens and you then pay it off, you can owe US tax on a currency gain even though you repaid exactly what you borrowed. Because Swiss owners often keep a big mortgage for decades, this matters more here than almost anywhere. Our guide to currency gains on a foreign mortgage shows the math.
Costs side by side
Rates as of November 2026.
| Zurich | San Francisco (the US example) | |
|---|---|---|
| Can you buy? | B permit: one home you live in; C permit: freely; non-resident: generally no [1] | Yes, no approval |
| Purchase taxes | No transfer tax in the canton of Zurich [3] | City transfer tax on a sliding scale that climbs steeply for high-value sales |
| Notary and registry | Notary about 1‰ of price plus VAT, land registry about 1‰; about 2‰ more on the mortgage note [4] | Escrow, title insurance and recording fees |
| Agent fees | Usually paid by the seller | Customarily paid by the seller |
| Annual property tax | No separate yearly property tax in the city; the home counts toward wealth tax, and imputed rent is taxed as income until 2029 [8] | Proposition 13 caps the base rate and yearly increases in assessed value; local add-ons on top |
| Tax on selling | Property gains tax 10% to 40%, surcharges under two years, discounts from five years; deferral when you buy a replacement home in Switzerland [5] | Federal and California income tax after Section 121 |
| US tax on the gain | Yes, worldwide, in dollars [6] | Yes; Section 121 if you pass 2 of 5 years [6] |
Illustration only. On a CHF 1.5 million apartment in Kreis 6 (about USD 1.82 million), notary and land registry fees at about 1‰ each come to roughly CHF 3,000 (about USD 3,650) plus VAT on the notary's part [4]. That's pocket change next to San Francisco's transfer tax at a similar price. The down payment is where Zurich bites: a fifth of the price is CHF 300,000 (about USD 364,500).
Tax when you sell
The Swiss side
In Switzerland a gain on private real estate isn't part of income tax; the canton taxes it separately. In Zurich, the property gains tax (Grundstückgewinnsteuer) [5]:
- runs progressively from 10% to 40%, with the top rate reached at a gain of about CHF 100,000; gains under CHF 5,000 aren't taxed;
- adds 50% to the tax if you sell within a year, and 25% within two years;
- cuts the tax by 5% after five full years, rising in 3% steps to 50% after 20 years;
- can be deferred if you sell a home you lived in and buy another one to live in, in Switzerland, generally within two years.
Notary fees, the original purchase costs and value-adding renovations reduce the taxable gain [5]. A deferral is a Swiss break only; the IRS doesn't follow it.
Holding costs are changing too. Swiss voters approved abolishing the tax on imputed rental value (Eigenmietwert), and the Federal Council set it to take effect on January 1, 2029. Mortgage interest and upkeep on your own home stop being deductible at the same time, apart from a limited break for first-time buyers [8]. Our guide to Swiss taxes for Americans has the rest.
The US side
Uncle Sam taxes your worldwide gain, measured in dollars:
- Section 121 can cover a Zurich home. Own it and live in it for at least 24 months of the 5 years before the sale, and up to USD 250,000 of gain (USD 500,000 for most joint filers) is excluded. You generally can't use it again within two years [6]. With Zurich prices, a gain above that is very possible.
- The franc moves the math. A strong franc can turn a modest gain in francs into a big one in dollars.
- The foreign tax credit. Zurich's property gains tax is a tax on a gain, and you can generally claim it on Form 1116 against US tax on the same gain [7]. Imputed-rent income tax and wealth tax are a different story. A US expat tax preparer can check what qualifies in your case.
- Depreciation recapture. If you later rent the home out (with a C permit), gain from depreciation after May 6, 1997 can't be excluded [9].
Your old home in San Francisco
The 2-of-5-years clock keeps ticking after you move. Stay away more than three years and the exclusion on your San Francisco home is usually lost, and California can still tax the gain on California property while you live in Zurich. Our guide to selling your US home after moving abroad covers the timing.
Renting it out
The Swiss side. On a B permit you can't rent out any part of the home you bought [1]. With a C permit you can, and rent is taxed as ordinary income, with deductions for upkeep and mortgage interest. Zurich's tenant protection is strong, so check the rules before you sign a lease.
The US side. Report the rent on Schedule E. A Zurich apartment is used predominantly outside the United States, so you must depreciate the building under the Alternative Depreciation System (ADS) over 30 years, not the 27.5 years a San Francisco rental gets [10][11]. Swiss income tax on the rent can be credited on Form 1116 [7].
If the rental is your place back home, see rental income from a US property.
Which makes sense for whom
- Staying long term, on a C permit. Zurich can make sense, especially past the five-year line when the gains tax starts to shrink. Live in it two of the five years before a sale and Section 121 helps on the US side.
- On a B permit. You can buy today, but the proposed rule change could add an approval step and new limits. Many Americans wait for the C.
- Retiring in Switzerland. Possible if you're already settled, though a retirement-only permit is hard for Americans to get. Plan the estate: cantons tax inheritances their own way and the US taxes your estate too. See wills and estate planning across two countries.
- Moving back in a few years. Renting is the no-brainer. A quick sale carries a Zurich surcharge, and the down payment would sit in a currency you're about to leave.
A US expat tax preparer (or a Swiss tax adviser) can check your situation before you sign. Swap notes with other buyers in our community group for Americans in Switzerland at /join/.
Sources
- Guidelines on the acquisition of real estate by persons abroad (updated July 2026) – Federal Office of Justice
- Revision Lex Koller – Federal Office of Justice (consultation April 15 to July 15, 2026)
- Handänderungssteuer in der Schweiz – Comparis (October 2026)
- Notariatsgebühren im Kanton Zürich – Neho
- Grundstückgewinnsteuer Zürich – Comparis
- Topic no. 701, Sale of your home – IRS
- Foreign tax credit – IRS
- Abolition of imputed rental value to enter into force on January 1, 2029 – Swiss Federal Council (April 1, 2026, in French)
- Publication 523 (2025), Selling your home – IRS
- Publication 527 (2025), Residential rental property – IRS
- 26 U.S. Code § 168, alternative depreciation system – Cornell Law School LII