FTA VAT practice related to blockchain and distributed ledger technology (DLT).
The Swiss Federal Tax Administration (FTA) has already published its VAT practice in connection with blockchain and distributed ledger technology (DLT) for the first time in 2019. However, these practice determinations are incomplete in certain areas and have gaps. A revision is urgently needed.
Self-employed activity and allocation of services under VAT law - The crux of external appearance
In August 2021, the Federal Administrative Court ruled in two cases on the question of whether the fact of independence as an explicit requirement for a subjective tax liability was fulfilled. Directly linked to the question of independence is the assessment of the external appearance, i.e. an outwardly perceptible, independent appearance as a service provider. At the same time, the VAT Act links the external appearance to the assessment of which taxable entity the objective facts of the service provision, in short, to whom the turnover achieved is to be allocated. The independence required for tax liability and the allocation of services are thus interlinked on the basis of the external appearance as a common criterion.
Sale of own shares - a service within the meaning of the VAT Act?
In its ruling 2C_891/2020 of 5 October 2021, the Federal Supreme Court upheld the Federal Administrative Court and decided, contrary to administrative practice, that the sale of treasury shares does not constitute a supply of services within the meaning of Art. 18 para. 1 VAT Act and is therefore outside the scope of application of VAT. This article is a brief analysis of the Federal Supreme Court's decision.
Relocation of businesses, functions and assets for profit tax purposes under VAT law
Within the framework of the STAF, a legal basis for the recording of cross-border inbound and outbound relocations of operations, functions and assets has been created at the federal, cantonal and municipal level. The question arises as to how such relocations should be treated for VAT purposes. The treatment is particularly relevant for inbound relocations in industries with a reduced input tax rate. As an outflow of the "dual entity" approach, relocations within the same legal entity between headquarters and permanent establishment are of interest.
FTA publishes two drafts on the VAT practice adjustment
On October 24, 2025, the FTA published two drafts on VAT practice on its website.
Signing and opening of the consultation on the protocol of amendment to the AEOI Switzerland-EU in tax matters
The Protocol of Amendment to the Agreement on the Automatic Exchange of Financial Account Information to Promote Tax Compliance in International Matters, signed on October 20, 2025, adapts the agreement to the amended OECD standard and supplements it with new provisions on administrative assistance in the collection of VAT claims. The consultation will last until February 6, 2026.
VAT accounting modalities can be adjusted directly online
On September 8, 2025, the FTA announced that the VAT settlement modalities can now be adjusted directly in the "VAT settlement" online service.
Extension of the deadline for submitting VAT returns
In its communication dated September 1, 2025, the FTA points out that deadline extensions for VAT returns can only be requested via the "VAT return" ePortal service.
Temporary continuation of the special VAT rate for the hotel industry
The special VAT rate of 3.8% for the hotel and para-hotel industry is to be continued for eight years. The Federal Council opened the consultation process at its meeting on August 13, 2025.
FTA - Reporting procedure and enclosures for contribution taxation are now submitted electronically with the VAT return
On March 10, 2025, the FTA announced that the form for the notification procedure and the enclosures for the contribution tax must now be uploaded and submitted directly in the online VAT return.
Current developments in VAT law (2020)
Workshop on the occasion of the ISIS) seminar on 2/3 March 2020 entitled "Corporate Tax Law 2020".
Institutions d'utilité publique et TVA
Workshop on the occasion of the ISIS seminar of 20 November 2019 entitled "La fiscalité de la philanthropie".
ISIS) seminar "VAT. Up-to-date. Compact. Interdisciplinary. (2019)" (seminar folder)
Case studies, detailed solution notes and slides: Here you will receive all documents (workshops and presentations) according to the following description from the ISIS) seminar "VAT. Up-to-date. Compact. Interdisciplinary." on 26 September 2019 under the direction of Harun Can and Roger Rohner, which took place at the Swissôtel in Zurich.
