The Case: In its 2016 corporate tax return, A. Ltd. claimed a warranty provision of CHF 7 million concerning potential warranty liabilities arising from a major construction project involving the expansion of an industrial facility. The company participated in the project through a joint venture. The Tax Administration of the…

The Case: The Federal Supreme Court had to determine whether the 795 shares bequeathed to a long-standing managing director and member of the board of directors under an inheritance agreement constituted taxable income or a bequest. A further issue was whether the authorities concerned had standing to bring an appeal…

The Case: A taxpayer claimed an input VAT deduction for consulting services. The Federal Administrative Court rejected the claim, among other reasons, because the services had been obtained prior to the commencement of the taxpayer’s VAT liability. The Commentary: The Swiss Federal Supreme Court overturned this approach, making clear that…

The Case: The Federal Direct Tax Act (DBG) does not expressly define the concept of “income.” The Commentary: Instead, Art. 16 para. 1 DBG contains a broad general clause based on an economically connecting factor. While this approach somewhat reduces legal certainty, it enables the taxation of economic benefits that…

The Case: The brochure uses illustrations and cartoons to provide an easy-to-understand overview of income taxes and wealth taxes for individuals, focussing on topics relevant to young and first-time taxpayers. The Commentary: As English is not one of the official languages in Switzerland, only key information is available in English.…

The Case: In 2024, Switzerland implemented the OECD minimum tax for large multinational corporations. The Commentary: A recent study by the University of St. Gallen (HSG) has since triggered a lively debate. The Institute of Law and Economics, led by Peter Hongler, argues that Switzerland should reconsider its participation in…

The Case: The Federal Tax Administration (FTA) has launched its new portal, combining its main online services on one centralised platform. The Commentary: The portal provides a clear overview of available services, with authorisations and applications now consolidated in a single location for easier access and management. For more information,…

The Case: Administrative assistance (DTA CH–US); group request: The IRS requested that a bank provide an unredacted version of a Swiss bank’s II.D.2 report listing accounts with a presumed US nexus lacking proof of US tax compliance. The Commentary: The Federal Supreme Court’s expansive approach to international administrative assistance has…