Are you planning a large-scale operation but are unsure of the tax implications? Then you may wish to submit the tax treatment that you plan to implement to the tax authority. Indeed, all natural and legal persons can contact their relevant tax authority to request validation for the tax treatment of an upcoming transaction.

The tax authority may:

  • Validate the tax ruling: if the tax treatment of the operation is carried out in an identical manner to that presented in the tax ruling, the tax authority will not be able to question the tax treatment. The tax ruling is protected by the principle of ‘good faith’.
  • Validate with reserve: the authority validates the request provided that certain highlighted points are respected.
  • Refuse the tax ruling: if the authority considers the project’s tax treatment to be incorrect, it may decide to refuse the tax ruling. In this case, the taxpayer may re-evaluate the tax implications relating to his/her project and re-submit the request.

Tax ruling: examples

A tax ruling request may be submitted for:

  • Obtention of holding company tax status
  • Obtention of ancillary business tax status
  • Dividend payment outside of Switzerland
  • Etc.

Tax ruling: procedure

The natural or legal person submits the facts of their given situation to the relevant tax authority before implementing their project, requesting that the authority validate the tax treatment outlined. This request can be made via a letter.

Depending on the reply from the tax authority, the project may go ahead and be taxed as indicated in the tax ruling, or else certain adjustments may be made at the authority’s request.

Certain projects are highly complex and represent the basis of complicated tax calculations. We advise you to contact our team of tax and legal experts, who will support you and offer you the optimal solution for your situation. They will also contact the tax authority to help ensure that your project goes ahead in strict compliance with current tax regulations.

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