Overview of the tax rulings of the Swiss Federal Administrative Court published between October 27 and November 2, 2025:

  • Judgment of October 1, 2025 (A-1276/2025): Customs (security line); The dispute is based on criminal and administrative proceedings for gold smuggling from Italy to Switzerland with Germany as the country of destination. The total quantity determined amounted to around 7,000 kg of gold with a value of around CHF 280 million, resulting in a claim of around CHF 25 million (including default interest) being asserted against the defendant/debtor. While the criminal proceedings have not yet been legally concluded, the payment request has become legally binding without being contested. As the debtor is domiciled abroad, the FOCA ordered that the claim be secured. The complainant essentially argued that the tax claim could not be asserted as the criminal proceedings had not yet been concluded. This argument was rejected by the FAC, in particular with reference to the legally binding payment request. The debtor's appeal was dismissed.
  • Judgment of October 1, 2025 (A-1036/2025): Customs (provision of security, seizure); The judgment was based on the same facts as the previous judgment of October 1, 2025 (A-1276/2025). However, this judgment also included the seizure of seized assets worth CHF 800,000. Both the seizure and the seizure of the customs claim owed were confirmed by the FAC. Dismissal of the debtor's appeal.

Decisions are listed chronologically by publication date.