Decisions of the Swiss Federal Administrative Court (CW 41–2026)

Overview of the tax law decisions of the Swiss Federal Administrative Court published between October 5 and October 11, 2026:

Updates / Republications:

A-2267/2022 (Withholding Tax (Refund); Decision Appealed to the Federal Supreme Court)
A-6593/2024 (Customs; Additional Assessment of Customs Duties and Import Taxes; Decision Appealed to the Federal Supreme Court)
A-3645/2023 (Withholding tax; calculation of late-payment interest; decision appealed to the Federal Supreme Court)
A-683/2025 (VAT, tax periods 2014–2019; decision appealed to the Federal Supreme Court)
A-1366/2026 (Withholding Tax (Refund, Permanent Establishment); Decision Appealed to the Federal Supreme Court)
A-7500/2024 (VAT (2019 tax period; input tax deduction on demolition costs and remediation of contaminated sites); decision appealed to the Federal Supreme Court)
A-6887/2025 (Withholding tax; assessment, de facto liquidation, liquidators’ liability; decision appealed to the Federal Supreme Court)
A-4538/2025 (VAT; taxable amount, tax differences (tax periods 2017 through 2020); decision appealed to the Federal Supreme Court)
A-1048/2026 (VOC tax; correction of the 2024 financial statements, additional assessment; decision appealed to the Federal Supreme Court)
A-2961/2026 (VAT, tax periods 2016 through 2020; supplies to closely related parties, input tax adjustment; decision appealed to the Federal Supreme Court)
A-1618/2026 (VAT (tax periods 2018 through 2020; input tax deduction); decision appealed to the Federal Supreme Court)
A-1652/2025 (VAT 2016–2019; purchase tax; decision upheld by the Federal Supreme Court in its judgment of August 5, 2026 (9C_492/2025))
A-6987/2025 (Direct Federal Tax, 2016 Tax Year; Interim Decision Regarding the Suspension of Proceedings to Determine the Place of Assessment; In its decision of August 28, 2026, the Federal Supreme Court declined to hear the appeal (9C_173/2026))
A-5498/2024 (VAT 2016–2018; input tax adjustment for tax exemption on contributions / input tax deduction; decision upheld by the Federal Supreme Court in its judgment of August 27, 2026 (9C_680/2025))

Administrative assistance (incl. updates / republications):

A-861/2024 (Administrative Assistance (Tax Treaty CH-FR))
A-2770/2025 (Administrative Assistance (MAC-UA); decision appealed to the Federal Supreme Court)
A-2350/2025 (Administrative Assistance (CH-US Tax Treaty); decision appealed to the Federal Supreme Court)
A-543/2026 (Administrative Assistance (DTA CH-IT); decision appealed to the Federal Supreme Court)
A-472/2026 (Administrative Assistance (DTA CH-IT); decision appealed to the Federal Supreme Court)
A-4064/2026 (Administrative Assistance (Tax Treaty CH-DE); decision appealed to the Federal Supreme Court)
A-4063/2026 (Administrative Assistance (Tax Treaty CH-DE); decision appealed to the Federal Supreme Court)
A-2349/2025 (Administrative Assistance (CH-US Tax Treaty); Decision appealed to the Federal Supreme Court)
A-4061/2026 (Administrative assistance (DTA CH-DE); decision appealed to the Federal Supreme Court)
A-5587/2025 (Administrative Assistance (MAC); decision appealed to the Federal Supreme Court)
A-4066/2026 (Administrative Assistance (Tax Treaty CH-DE); decision appealed to the Federal Supreme Court)
A-8756/2025 (Administrative Assistance (MAC-SI); Decision appealed to the Federal Supreme Court)
A-2744/2025 (Administrative Assistance (CH-US Tax Treaty); Decision appealed to the Federal Supreme Court)
A-3286/2025 (Administrative Assistance (CH-US Tax Treaty); decision appealed to the Federal Supreme Court)
A-3365/2025 (Administrative Assistance (DTA CH-US); decision appealed to the Federal Supreme Court)
A-5627/2025 (Administrative Assistance (MAC-IL); In its decision of August 24, 2026, the Federal Supreme Court declined to hear the appeal (2C_463/2026))