In concretisation of Art. 14 StG, Circular No. 24 of the Federal Tax Administration (FTA) of 20 November 2017 on collective investment schemes as subject to withholding tax and stamp duties states that non-cash expenses in the form of taxable deeds by an FCP, a SICAV or a KmGK to the investor are not subject to turnover tax.
Based on various Ruling requests, the FTA sets forth in its January 12, 2021 Notice when such a factual issue exists.
The communication is available here.
