Overview of tax rulings by the Swiss Federal Administrative Court published between December 8 and 14, 2025:
- Judgment of November 21, 2025 (A-4047/2024): VAT 2018-2022; Withholding tax in the case of an insurance broker not subject to domestic tax; Services not subject to withholding tax in the context of activities as an insurance broker. In the present case, the (only withholding) taxpayer acted as an insurance broker for an insurance company. The taxpayer purchased services from B LLC, which is based abroad. In the taxpayer's opinion, B LLC provided services to it as a sub-broker in the online sale of legal expenses insurance, which is exempt from tax under VAT Act 21(2)(18)(d). The FTA, on the other hand, was of the opinion that it had not been proven that the services purchased (or the remuneration paid for them) corresponded to those exempt from tax under this provision. The Federal Administrative Court shares the FTA's view. As this is a tax-reducing factor, the burden of proof lies with the taxpayer. The service received was therefore subject to input tax. The taxpayer's appeal was dismissed.
Administrative Assistance:
Decisions are listed chronologically by publication date.
