For years, wealthy foreigners have
made a beeline for Switzerland because of its attractive lifestyle and scenery, political stability and banking services. For a few, that affinity has turned permanent thanks to laws that allow super-rich foreigners to become residents through tax deals with local authorities.
Among Switzerland's "rich list" are some of the world's wealthiest families, including Ingvar Kamprad of the Ikea chain, Otto Beisheim of German retailer Metro, and the Brenninkmeijers of fashion group C&A. Stars such as Phil Collins and Michael Schumacher have also been drawn, as much by the prospect of relative anonymity and personal security as by
tax savings.
Some 3,500 super-wealthy non-Swiss now benefit from special rules that disregard their foreign wealth and income and instead set
flat-rate tax payments, based on a multiple of annual housing costs. Almost a third live in the French-speaking canton of Vaud. Another 600 or so reside in and around Geneva. Valais, Ticino and the Grisons are also popular.
The Swiss defend the system, founded in Vaud in 1920, as a source of bonus revenue from people who would otherwise live in alternative
low, or no, tax jurisdictions such as Monaco or the UK Channel Islands. Together, the "special cases" contribute about SFr300m (EUR185m) a year in tax and also boost investment and jobs.
Of course, every so often, the normally forgotten exiles cause a stir as a high-profile newcomer joins their ranks. The most recent episode suggests that attitudes may be changing - in Switzerland, too. At Christmas, Johnny Hallyday, the veteran French rock star, announced he was
decamping to the millionaires' retreat of Gstaad after becoming fed up with paying six out of every 10 euros he earned to the French trésor.
Mr Hallyday's decision prompted the predictable storm in France. Unusually, however, it also triggered debate in his newly adopted country. Doris Leuthard, Switzerland's new economics minister, publicly questioned why such figures should be allowed to save a fortune in tax when equally prominent Swiss citizens, such as tennis star Roger Federer, presumably paid heavily.
Her comments were made at a sensitive time. Switzerland has been fencing with the European Commission over whether its differential cantonal taxes for companies - each of the 26 cantons can set its own
levy - constitute unfair competition under the
free trade agreement between Bern and Brussels.
Swiss experts say the accusation is
baseless. But the fight has come just as Switzerland has scored a number of successes, attracting several high-profile companies to set up shop. Recently, Kraft said it was
ditching London and Vienna for a new European HQ in Zurich - leaving a sour taste in the UK and Austria.
While most Swiss applaud such victories, the special rules for millionaires are more
divisive. Until Ms Leuthard's outburst, however, demands for their abolition had been restricted to the Social Democrats, Switzerland's second biggest party.
Ms Leuthard, whose comments may just have been a populist ploy to boost her ailing Christian Democrats, was swiftly slapped down by colleagues in the coalition government. Some dismissed her remarks as a faux pas by an inexperienced newcomer. Hans-Rudolf Merz, the finance minister, defended the rules
staunchly. He argues that the UK and Belgium also offer rich foreigners special treatment.
But change may be in the air. This month, cantonal finance officials discussed doubling the average SFr75,000 paid by rich foreigners each year and setting a floor of SFr80,000. Although they came to no decision, the fact the matter was raised at all was significant. It may gain weight in 2007, a federal election year. In time, tax rates might even rise - not that most foreign
beneficiaries would notice.