According to the Federal Tax Administration's (FTA) communication of 17 February 2020, autonomous departments of the same community may merge to form a single tax entity. It is possible to form several mergers or to combine all departments into a single taxable entity (Art. 12 para. 2 MWSTG). With regard to the corporate tax, only the association is then liable to pay the tax (Art. 70 para. 2 RTVA) and not the individual members. The corporate tax rate is determined on the basis of the cumulative total turnover of the concentration (Article 70(3) RTVA). Applications for the formation of mergers must be submitted by the end of February.
The communication is available here.
