Tax Newsletter Switzerland

The amending protocol is applicable as of 1 January 2024 and replaces a corresponding mutual agreement. From this date, frontier workers have the option of working from home for up to 25% of their working time without any change to the applicable taxation rules or frontier workers status.

For more information, see the following link.

Stay ahead of latest developments on Pillar Two implementation. Our Country Tracker provides the status of Pillar Two implementation in different countries and regions as well as a comprehensive summary of compliance and registration deadlines. 

You can access the tool at the following link.

For ongoing updates from the international tax world, we recommend our international Tax News, which you can access at this link.

The GloBE Information Return (GIR) application is now available in the federal e-Portal, enabling companies to register for the GIR purposes with the Swiss Federal Tax Administration (SFTA) and submit their returns.

For further information, please visit this link.

On 5 January 2026, the OECD/G20 Inclusive Framework adopted administrative guidance introducing the Side-by-Side Package, which includes five safe harbour rules relevant for Pillar 2 implementation. Switzerland's Minimum Taxation Ordinance requires these rules to be interpreted according to OECD commentaries and applies these safe harbour rules automatically. The transitional Country-by-Country Reporting (CbCR) Safe Harbour is now extended to fiscal years starting by 31 December 2027, ending by 30 June 2029. Other safe harbour rules - Substance-Based Tax Incentive, Side-by-Side, and Ultimate Parent Entity (UPE) Safe Harbours - apply to fiscal years starting on or after 1 January 2026. The Simplified Effective Tax Rate (ETR) Safe Harbour applies from fiscal years starting 31 December 2025, with relevant Swiss ordinance provisions also governing its calculation.

For further information, please visit this link.

The Global Anti-Base Erosion (GloBE) Model Rules apply directly to international and Swiss top-up tax under Switzerland’s Minimum Taxation Ordinance (OMinT). The administrative guidance adopted on 13 January 2025 governs the application of transitional rules under Article 9.1 of the GloBE Rules, specifically concerning deferred tax assets (DTAs) from tax benefits or new taxes after 30 November 2021. Deferred tax expenses from DTA reversals are excluded from effective tax rate (ETR) calculations, subject to a time- and amount-limited grace period. On 15 and 18 December 2025, the Swiss Federal Chambers instructed the Federal Council to amend the OMinT so that the guidance applies only to benefits granted from 1 January 2025 onward. As this amendment likely won't be effective before the top-up return filing deadlines, entities must apply the current guidance and file returns on time without extensions. Taxpayers must disclose any ETR reductions within their returns. Final assessments by cantonal authorities will await the Federal Council’s decision on the amendment.

For further information, please visit this link.

The Swiss Federal Tax Administration (SFTA) has published the circular letters on the tax-recognised interest rates for 2026 for advances or loans in Swiss francs and foreign currencies.

These letters can be found under this link.

On 5 February 2026, the Swiss Federal Tax Administration (SFTA) published Circular 029-S-2026 regarding Securities Transfer Tax (STT) in the context of Employee Participation Plans. This communication clarifies the SFTA's administrative practice following a recent Federal Supreme Court ruling (9C_168/2023 and 9C_176/2023). The publication can be found under the following link.

Please find below the key updates:

• PSU/RSU plans: The Federal Supreme Court ruled that for PSU/RSU plans, no STT is due upon allocation of shares at vesting, as the transfer is considered to be without consideration. This marks a change in the SFTA's previous administrative practice.
• Definition of “consideration”(Entgeltlichkeit): The SFTA also clarified its practice on the consideration amount for various instruments (discounted shares, call options, and compensation paid in shares), which is subject to STT provided a Swiss securities dealer is involved. The SFTA confirmed that free shares granted without salary deductions are not subject to STT since they are provided without consideration.
• Effective date: The updated practice applies from the publication of the Federal Supreme Court ruling, i.e., 25 November 2024.

The calculatory interest rate was published for the 2026 tax year and amounts to 0.333%. The calculated interest rate on the security equity corresponds to the yield on ten-year federal bonds on the last trading day of the calendar year preceding the start of the tax period.

The publication can be found under the following link.

The Swiss Federal Tax Administration has updated the price lists and the bonus share lists for 2025.

The lists can be found at the following link.

The dossier tax information tax rates and multiplier has been updated.

The dossier can be found under the following link. 

On March 23, 2026, the Swiss Federal Tax Administration has adjusted the cantonal gazettes.

The cantonal gazettes can be found at the following link.

The Swiss Federal Tax Administration (SFTA) has released the conversion rates for the calendar year 2025 and as of December 31, 2025.

The publication can be found under the following link. 

The table overview of tax policy proposals and initiatives have been updated.

The overviews can be found under the following link.

Enclosed you will find a selection of the Swiss Federal Court (SFC) and Swiss Federal Administrative Court (SFAC) , that may be of interest to you:

• SFAC dated March 2, 2026: The Federal Administrative Court ruled that the free transfer of a patient base to the sole shareholder constitutes a monetary benefit, validating the withholding tax plus interest, and upheld the denial of the notification procedure.
• SFC dated February 23, 2026: The Federal Supreme Court ruled about a simulated loan, which had to be offset as a benefit in kind. In support, it referred in particular to the absence of a written loan agreement, and the fact that the loan represented about two-thirds of the company’s assets. The subsequent repayment of the loan including interest did not change this, since the tax assessment must be based on the time of the loan granting.
• SFC dated January 26, 2026: The Federal Supreme Court ruled that a (potentially) null dividend resolution does not prevent the emergence of the withholding tax claim even if it is annulled, provided that the directly affected parties (resolving shareholders) acted in bad faith. 
• SFC dated January 14, 2026: The Federal Supreme Court decided that the principle of good faith protects the foundation's legitimate expectation that the tax exemption continues to apply until an investigation into the tax exemption is initiated. 

The Grand Council of Aargau has approved a tax law revision. The revision includes several measures such as reducing corporate taxes for associations and foundations.

For more information, visit the link.

The canton of Fribourg announced, among other updates, a reduced capital tax rate is introduced for intra-group loans as of tax return 2025.  

For more details, visit this link.

As of January 1, 2026, the updates to the Lucerne Tax Book have been made available online. The homepage provides a list of these updates, allowing businesses and individuals to understand the changes affecting their tax responsibilities. Additionally, access to all archived versions is provided, offering comprehensive historical insight into past regulations. These updates are critical for maintaining compliance and understanding the tax landscape in Lucerne.

For more information, please refer to the original publication.Top of FormBottom of Form

The Canton of Schaffhausen has implemented a staggered enactment of its tax law revision, with no referendum challenges. Amendments align the cantonal tax law with the federal tax harmonization law, addressing international home office taxation, the treatment of collective investment schemes with real estate holdings, and mixed-economy companies.

For more details, refer to this link.

As of January 29, 2026, the guideline regarding the taxation of indirect partial liquidation and relocation (WiTT, Tax Book No. 70.23) has been abolished. The content previously covered by this guideline is now comprehensively regulated under § 21b of the tax law.

For more information, please refer to the tax law.

The tax multipliers for 2026 have been published, detailing the valid overall tax rates per municipality for both individuals and legal entities. This includes rates with and without church taxes.

The tax multipliers can be found under the following link.

The Canton of Zug has issued a revised ordinance and published the application form. The publication can be found under the following link.

There are some key amendments and clarifications which we would like to point out:

• Clarification on Emission Reduction: The revised ordinance states that the reduction of at least 50,000 tons of CO₂-equivalent emissions refers to the worldwide emissions at group level and not only to the local Zug group company.
• New requirement to be eligible for Outcome-based funding: To qualify for Outcome-based funding, the company must not only achieve a reduction of 50,000 tons of CO₂-equivalent emissions but also demonstrate that it incurred at least CHF 1.5 million in personnel expenses within the Canton of Zug.
• Clarification on emission reduction evidence: The revised ordinance specifies that “the proof … shall be provided using industry-standard impact indicators based on audited non-financial reporting or an audited greenhouse gas inventory. The industry-standard impact metrics must also have been audited by a state-supervised auditing firm.” According to our interpretation, an audited report (whether a non-financial report or a greenhouse gas inventory) is necessary as starting point, followed by an additional report audited by a Swiss state-supervised firm to confirm the reduction.
• Ordinary Audited Financial Statements: According to the revised ordinance, the application must include the audited annual accounts along with the accompanying report from the auditors.

The application window is open and the latest date to submit the application form is May 31, 2026. PwC offers assistance to help companies assess eligibility and maximise benefits under this new funding opportunity. For further information please see our flyer.

The publication outlines several updates and additions to the Zurich Tax Book.

For more information, visit this link.

The law and its implementation regulation establish the principle of taxation based on domestic consumption.

It is uncommon to see foreign entities registered for VAT purposes in China. This is because of the following two measures, with which the tax authority in China can collect the VAT owed by the foreign taxpayers: 

• If a foreign entity performs taxable transactions in China, in most of the cases, the foreign entity is not required to register for VAT in China because of the withholding mechanism, whereby the purchaser shall serve as the withholding agent.
• When an entity or individual taxpayer makes payment to a foreign entity, tax clearance is required before the payment can be remitted by the banks (China foreign exchange control rules).

Key takeaway: Foreign companies operating in China and/or with Chinese suppliers should be aware of this change in law and assess whether VAT registration is necessary based on their specific activities and transactions. Understanding local VAT regulations and compliance requirements is critical to avoid potential risks.

• Italy implemented an EU cross‑border VAT exemption scheme for small businesses: Eligible businesses can sell into other EU countries without charging VAT, but they also cannot reclaim related input VAT.
• Who can use it? EU-established taxable persons with low annual turnover. EU threshold for use of the cross-border VAT exemption regime = EUR 100,000 of total turnover in the European Union; Italy’s domestic annual threshold = EUR 85,000.
• Important distinction: If Italy is the destination (exemption) State, only individuals (entrepreneurs or professionals) who apply Italy’s flat‑rate regime (“regime forfettario”) qualify. If Italy is merely the State of establishment, other entities can also adopt the regime, where allowed by the rules of the Member State of establishment.
• How to join: Submit a prior notification to the Italian tax authorities, listing turnover details for the Member States where you’ll use the exemption scheme.
• Ongoing reporting obligations: File quarterly reports (similar to the One Stop Shop (“OSS”)) showing totals by Member State, even if no transactions occurred during the period. Non-compliance with reporting for two consecutive quarters may result in mandatory VAT registration in Italy.

The OECD published a report examining the design and operation aspects of Digital Continuous Transactional Reporting (DCTR) regimes, covering e-invoicing and digital reporting, for value added tax (VAT). A growing number of jurisdictions worldwide are introducing or have implemented a DCTR mandate as part of a broader shift toward more automated and data-driven tax administration.

These regimes typically require real-time or near real-time reporting of invoices or transactional data to the tax authorities, aiming to enhance VAT compliance and risk management. 

The report has been prepared in the context of a growing number of jurisdictions worldwide that have adopted or are considering the introduction of such regimes. It offers guidance to support jurisdictions in the design and operation of DCTR regimes, with a view to facilitating compliance and administration while promoting greater international consistency.

Key takeaways for businesses:

• As DCTR adoption grows, businesses must integrate tax compliance into digital workflows to align with the transaction-based nature of VAT and short reporting cycles.
• Companies engaged in cross-border trade should prepare for compliance with diverse DCTR requirements and monitor developments in international e-invoicing standards.
• Although primarily targeted at policymakers, the report provides valuable insights for businesses, including:
  • Stay informed about current global DCTR regimes (global) and their implications.
  • Assess how DCTR could impact relationships with tax authorities, particularly in areas like VAT recovery and potential audit risks.
  • Review the quality and accessibility of data required to ensure accurate DCTR reporting.
  • Proactively assess potential cash flow challenges, such as those arising from invoice rejections under the new regime, and plan accordingly.

The Spanish Government has approved a royal decree requiring electronic invoicing for all B2B transactions, aiming to reduce late payments and administrative burdens.

Implementation Timeline:

• The system will be phased in after the Ministry of Finance publishes technical specifications (expected before 1 July 2026).
• Businesses with annual turnover exceeding EUR 8 million will have one year to comply.
• All other businesses will have two years to comply.

Key Features:

• E-invoices must be structured, machine-readable files (not PDFs or paper).
• Businesses must electronically report invoice status, including acceptance and effective payment dates.
• The e-invoicing obligation will apply only to domestic B2B transactions, which means that cross-border B2B transactions when one party is not established or has a permanent establishment in Spain will be exempt.
• Two exchange channels:
  • Private platforms (interconnected to ensure flexibility).
  • A free public platform developed by the Spanish Tax Agency (AEAT) for all businesses or professionals, including small entities and self-employed individuals with low invoice volumes.

Alignment with EU Strategy: The decree aligns with the European Commission's VAT in the Digital Age (ViDA) initiative and develops Article 12 of Spain's "Ley Crea y Crece" (Law 18/2022).

Distinction from VeriFactu: The B2B e-invoicing mandate is separate from the VeriFactu system, which targets tax fraud and will take effect in 2027.

This reform represents a significant step toward digital transformation and compliance in Spain's business landscape.

Germany's Federal Ministry of Finance has abolished the VAT warehouse scheme, effective 1 January 2026, due to its limited use and high administrative burden.

Background on the VAT Warehouse Scheme: Previously, the scheme allowed VAT exemptions for certain transactions involving goods stored in approved warehouses. This included supplies of goods entering or remaining in such warehouses, as well as services directly related to storage, preservation, improvement of presentation, or preparation for distribution. VAT became chargeable upon release of goods from the warehouse.

Key Transitional Provisions:

• End of Exemption Upon Removal: Goods stored before 1 January 2026 lose their VAT exemption when removed from warehouses between 1 January 2026 and 30 December 2029. Goods still in storage on 30 December 2029 will be deemed removed, triggering VAT liability.
• Continued Exemption for Related Services: Services (e.g., storage, preservation, distribution preparation) remain VAT-exempt until 30 December 2029.
• Tax liability and the "Auslagerer": The party removing goods (the "Auslagerer") becomes liable for VAT on the last exempt transaction before removal. The Auslagerer must hold a German VAT identification number, and non-resident businesses must register for VAT in Germany.
• Joint liability for warehouse operators: Warehouse operators may be jointly liable if the Auslagerer fails to meet VAT obligations and proper records are not maintained.
• Documentation and Record-Keeping: Businesses must retain evidence proving exemption conditions for goods stored before 31 December 2025. Warehouse operators must maintain stock records and verify the Auslagerer's VAT identification number with the Federal Central Tax Office.
• Cross-Border Movements: Exemptions for export supplies or intra-Community supplies may apply if documentation requirements are met.

This change requires businesses to review their VAT compliance processes and ensure proper record-keeping during the transitional period.

A new CJEU ruling clarifies when loyalty points qualify as "vouchers" under the EU VAT Directive 2006/112/EC (as amended by Directive 2016/1065) - with important implications for retail and consumer businesses operating vouchers and discount structures.

• Swedish retailer Lyko Operations AB sought a ruling on whether a planned customer loyalty program - where customers earn points redeemable for bonus products - constitutes a "voucher" under Article 30bis of the VAT Directive.
• The CJEU held that loyalty points do not qualify as vouchers where the supplier has no obligation to accept them as consideration for a supply of goods or services. Instead, the points merely allowed the customer, when making a new purchase, to obtain additional low-value products as a bonus.
• This distinguishes discount-based loyalty schemes from true voucher arrangements, which carry different VAT treatment.

Clients operating voucher or loyalty programs should review their structures - now is a good time for a VAT health check.

France is implementing mandatory B2B e-invoicing and e-reporting in phases, starting 1 September 2026, for large and mid-sized companies, with all VAT-registered businesses included by 1 September 2027.

On 3 February 2026, the French Parliament adopted the 2026 Budget Law (Loi de finances pour 2026), introducing significant changes to France’s e-invoicing framework under Article 123.

While e-invoicing obligations apply only if the entity is established or has a fixed establishment in France, e-reporting obligations apply to French VAT registered companies with no permanent establishment in France.

Clients operating in France should prepare for the upcoming changes. Non-compliance will result in increased penalties.

Supreme Court Ruling and Immediate Executive Response

• On February 20, 2026, the US Supreme Court held that the International Emergency Economic Powers Act (IEEPA) does not authorize the President to impose tariffs, affirming the Federal Circuit and ending reliance on IEEPA for "reciprocal" and drug-trafficking tariffs.
• In immediate response, the President issued an Executive Order titled "Ending Certain Tariff Actions," directing agencies to terminate and cease collecting the additional ad valorem duties imposed under IEEPA across multiple prior executive orders.
• It expressly preserved all non-IEEPA tariffs, clarifying that duties imposed under Section 232 (national security) and Section 301 (unreasonable or discriminatory practices) remain unaffected.

Replacement Trade Measures

• Concurrently, the President invoked Section 122 of the Trade Act of 1974 to proclaim a temporary import surcharge of 10% ad valorem on virtually all imports for 150 days, effective February 24, 2026.
• The surcharge is treated as a regular customs duty and does not apply in addition to Section 232 tariffs.
• Enumerated exceptions cover certain critical minerals, energy products, pharmaceuticals, specified vehicles and parts, USMCA-compliant goods, and Section 232-covered articles.
• A companion Executive Order continues the global suspension of duty-free de minimis treatment, also effective for entries on or after February 24, 2026.

Court-Ordered Refunds and CBP Implementation

• On March 4, 2026, the United States Court of International Trade (CIT) issued an order directing the U.S. Customs and Border Protection (CBP) to liquidate any unliquidated entries subject to IEEPA duties without applying those duties, and to reliquidate entries that had already liquidated but were not yet final, removing the IEEPA duties.
• The CIT stated that importers whose entries were subject to IEEPA duties are entitled to the benefit of the Supreme Court's ruling.
• In a March 6, 2026, declaration filed with the CIT, CBP proposed developing new Automated Customs Environment (ACE) functionality to implement an automated, importer-based refund process for IEEPA duties, including interest, which it expected to be ready within approximately 45 days.
• The court subsequently paused the order requiring immediate refunds.
• CBP announced it is developing a new capability within ACE called the Consolidated Administration and Processing of Entries (CAPE) to facilitate IEEPA refunds. The Automated Commercial Environment (ACE) is the United States's centralized digital system for processing imports and exports.

New Section 301 Investigations

• On March 11, 2026, USTR launched new Section 301 investigations into structural excess manufacturing capacity across 16 economies, including China, the European Union, Singapore, Switzerland, and Norway.
• USTR requested consultations and opened public comments, due April 15, 2026, ahead of a hearing beginning May 5, 2026.
• On March 12, 2026, USTR initiated Section 301(b) investigations into 60 (including EU, Switzerland, Norway, Japan or UK) of the United States’ largest trading partners to assess whether their failure to impose and effectively enforce bans on imports of goods made with forced labour is unreasonable or discriminatory and burdens U.S. commerce; USTR has requested government-to-government consultations, and is accepting public comments and hearing requests until April 15, 2026, and will hold hearings beginning April 28, 2026.

Parliament and Council reached a political agreement on the EU Customs Reform, which the Commission describes as a landmark, data-driven revision of EU Customs Code which streamlines procedures, establishes definition of the “Importer of Record” and introduces targeted e-commerce measures.

• New Handling Fee: A fee will apply to parcels sent directly from non-EU countries to EU consumers, starting no later than November 2026. A temporary €3 flat customs duty per low-value item will also apply from 1 July 2026.
• Platform Responsibility: E-commerce sellers and platforms acting as importers must ensure customs compliance and payments, with strict penalties for non-compliance.
• "Trust and Check" System: Simplified procedures will be available for vetted companies cooperating with customs, allowing faster clearance and more flexible payments. The Trust & Check category strengthens the already existing Authorised Economic Operators (AEO) programme for trusted traders.
• EU Customs Data Hub: A centralized system will replace hundreds of legacy software platforms, improving risk analysis and customs cooperation, with full transition targeted by 2034.
• New EU Customs Authority: Based in Lille, France, this authority will oversee cooperation, risk management, and data hub operations.

By 2034, all traders will fully transition to the Data Hub, making it the sole mandatory EU customs entry point.

The EU and India concluded negotiations on the Free Trade Agreement (FTA) on 27 January 2026, the largest trade deal either side has ever made, creating a free-trade zone covering roughly 2 billion people.

India will eliminate or reduce tariffs on 96.6% of EU goods exports, with overall savings for EU exporters estimated at about €4 billion annually and an expectation that EU goods exports to India will double by 2032.

Industrial tariffs will face major cuts: car duties fall from 110% to as low as 10% (with a quota of 250,000 units), car parts go to 0% after five to ten years, and most tariffs on machinery, chemicals, and pharmaceuticals drop to 0% over transition periods of up to ten years.

The agreement grants privileged access to India’s services market, with India making its most ambitious financial services commitments in any trade deal to date, including in areas like maritime transport.

Scope of tariff elimination is sweeping: the EU will eliminate tariffs on over 90% of tariff lines (91% by value) and India on 86% of lines (93% by value), with partial liberalisation bringing overall coverage to 99.3% for the EU and 96.6% for India.

Next steps include publishing the negotiated texts, legal review and translation, Council decisions for signature and conclusion, European Parliament consent, and India’s ratification before entry into force; parallel negotiations on Geographical Indications and an Investment Protection Agreement continue.

The EU and Australia concluded negotiations on a free trade agreement in March 2026; the deal removes over 99% of tariffs on EU exports to Australia, improves access to critical raw materials, and strengthens strategic ties with the Indo-Pacific, alongside a new Security and Defence Partnership.

From day one after entering into force, tariffs will be eliminated on key EU industrial exports such as machinery, motor vehicles, and chemicals, unlocking immediate price and competitiveness gains in the Australian market while removing over 99% of tariffs on EU goods overall.

Services market access improves for EU firms in professional and business services, maritime transport, and financial services, while digital trade rules set clear disciplines on cross-border data flows and prohibit data localisation requirements, providing legal certainty for tech-enabled business models.

To secure supply chains for the green and digital transitions, the agreement prioritises access to Australian critical raw materials such as aluminium, lithium, and manganese, reduces or removes tariffs on these inputs, and deepens cooperation, including potential co-financing of projects and sustainability provisions governing extraction and safety.

The agreement provides predictability and legal certainty through stable, transparent rules, helping businesses of all sizes plan for long-term growth in Australia while diversifying the EU’s global trade partnerships and strengthening supply-chain resilience.

Swiss companies have historically been permitted to act as customs declarants at Swiss-EU border customs offices (e.g., HZA Lörrach and Singen in Germany), as reflected in Article 170(3)(c) of the Union Customs Code (UCC). This facilitated DDP (Delivered Duty Paid) deliveries to EU customers using procedures such as 40 or 42.

The amendment to Article 25 of the EU CBAM Regulation introduced a requirement for non-EU-established entities importing goods into the EU to use an indirect customs representative. This indirect representative must register for CBAM purposes, even if the importer's volumes fall below the 50-tonne annual threshold.

The CBAM obligation effectively nullifies the historical exemption under the UCC that allowed Swiss companies to act as declarants in the border area. German customs authorities take the position that the special legislation under the CBAM Regulation takes precedence over the UCC.

For goods falling under CBAM tariff codes, Swiss companies making DDP deliveries must now engage an indirect customs representative who also acts as the CBAM declarant, including in border areas.

Potential for future change: This requirement may be revisited in the short to medium term if Switzerland negotiates an alternative arrangement with the EU.

Pursuant to revised customs regulations effective from 27 February 2026, the South African Revenue Service (SARS) will regard post-year-end transfer pricing adjustments that increase the transfer price (such as debit notes) as subsequent proceeds to be included in the customs value. Accordingly, importers are required to amend the original customs declaration and ensure any additional customs duty and VAT are properly accounted for.

Transfer pricing adjustments that decrease the price (i.e., credit notes) require a downward amendment to the originally declared customs value. Consequently, importers may apply for a refund of duties under the Customs Act’s refund provisions after making the amendment.

All debit and credit notes relating to imported goods must be reported to SARS within one month of receipt, which makes timely monitoring of year-end transfer pricing true-ups critical for customs compliance.

Where transfer pricing adjustments affect the price of imported goods, the customs value declared at the time of import must be amended accordingly.

It shall be highlighted that SARS increasingly scrutinizes transfer pricing adjustments and related-party payments by reviewing corporate income tax returns and foreign payment data and frequently requests transfer pricing documentation during customs reviews.

Amendments to the Executive Regulation (Decision No. 548 of 2025)

• AEO eligibility expanded from "companies" to any "applicant," broadening access to Authorized Economic Operator status.
• Advance inquiries on tariff classification, origin, and customs systems are now advisory and non-binding, valid for six months.
• Warehousing period extended from nine months to one year, with partial release permitted up to three times (extendable to nine with approvals).
• Temporary customs warehouses introduced within ports for goods imported for circulation; storage limited to one month for hazardous goods, two months for general goods, and condition-dependent for perishables.

Advance Rulings Regulation (Decision No. 549 of 2025)

• Binding advance rulings introduced for tariff classification and origin, aligned with the WTO Trade Facilitation Agreement.
• Rulings are binding on both the Customs Authority and the applicant - one year for classification, three years for origin - but may be cancelled if based on inaccurate or misleading information.

What you need to know

• The Digital Product Passport (DPP) is a core element of the EU’s Sustainable Products framework and will introduce new data, transparency and traceability requirements across product value chains.
• Companies placing products on the EU market will need to collect, manage and share structured product information covering sustainability, compliance and lifecycle aspects.
• While implementation timelines differ by sector, preparations need to start now to align governance, data, and technology capabilities.

Webinar highlights

• We recently hosted a webinar on the Digital Product Passport, focusing on regulatory expectations, practical challenges, and early implementation considerations.
• The session explored what DPP means in practice, how it links to existing compliance obligations, and how organisations can turn regulatory readiness into strategic advantage.

Watch the recording here 

The EU Packaging and Packaging Waste Regulation (PPWR) has entered into force in February 2025 and will fully apply from 12 August 2026, introducing harmonised EU‑wide requirements on packaging reduction, recyclability, recycled content, labelling, reuse obligations, etc.

Many implementation details and practical implications are now moving into focus, and we are actively supporting this discussion through a series of upcoming PPWR webinars: on one side we have two sessions organised with the Switzerland Global Enterprise in German and in Italian, and a client‑focused PwC webinar. Registration links for the PwC webinar will be shared once available.

On 30^th March the EU Commission published further guidance to support the implementation of the new packaging rules. The guidance document and FAQ published clarify interpretation of the regulation and address more complex practical topics. Several delegated and implementing acts are under preparation in close cooperation with Member States.

Developments continue under the EU Deforestation Regulation (EUDR). Following the targeted revision adopted in December 2025, the European Commission is required to carry out a simplification review and publish a report by 30 April 2026, which may be accompanied by further legislative proposals.

While the core objectives and scope of the EUDR remain unchanged, this review is expected to address implementation challenges and administrative burden, making the coming months particularly important for companies preparing their compliance approach.

In this context, we are also hosting an EUDR roundtable on 7^th May; colleagues with client interest are invited to contact us for further details.

• Direct Uploads: Forms for the notification procedure and attachments for subsequent input tax deductions (“Einlageentsteuerung”) must now be uploaded directly in the VAT reporting section of the ePortal. The option to upload documents will appear once the figures are entered in the respective VAT return box.
• Declaration of Import VAT: VAT-registered companies using the transfer procedure (“Verlagerungsverfahren”) must declare import VAT online via the ePortal.
• Changes for Flat Tax Rate Method: Adjustments to VAT declarations under the flat tax rate method apply due to a partial revision effective 1 January 2025.
• Reporting Adjustments: Updates to reporting modalities can now be captured directly in the system.

Timeline for the new ESTV Portal:

• 8 May 2026: Integration of withholding tax, stamp duties, VAT, and radio/TV fees into the ESTV Portal.
• May 2026: Shutdown of the "MWST-Abrechnung easy" service.
• 1 January 2027: New features added to the ESTV Portal, including VAT deregistration and VAT group management (creation, modification, and deletion).

What Actions Are Required?

• Existing VAT users: No action is needed. Current services will remain available. Only the access and path to the service will change.
• New users or "MWST-Abrechnung easy" users: Registration and access to the ESTV Portal will be via the Swiss Federal Tax Administration’s website or the ePortal.

Shutdown of "MWST-Abrechnung easy":

• The "MWST-Abrechnung easy" service will be discontinued on 8 May 2026, with VAT reporting transitioning to the new ESTV Portal.
• The new portal will offer enhanced security standards, including AGOV integration.

AGOV – The New Swiss Authorities Login:

• Introduction of AGOV: AGOV is the new unified login system for accessing federal, cantonal, and municipal authorities in Switzerland.
• Launch Date: AGOV is available for use in the existing ePortal since 7 September 2025.
• Mandatory for New Users: From 15 May 2026, new users (e.g., new taxpayers) must use AGOV to register. Registration with CH-Login will no longer be possible, though existing CH-Login users can continue using it temporarily.
• Full Transition: By spring 2027, AGOV will become mandatory for all users, and CH-Login will no longer be supported.

For further details or assistance with the transition, feel free to reach out to us.

Planned Increase in VAT Rates:

• Federal Council proposes a temporary increase of 0.8% from 2028, earmarked for security and the armed forces.
• Additional increase of 0.7% to 1.0% under discussion to fund the 13th AHV pension.
• Potential Impact: VAT rates could potentially rise to 9 - 10%, depending on the final design and bundling of measures.

Next steps:

• Parliamentary deliberations to begin in autumn 2026.
• A referendum, requiring a double majority of the people and cantons, is likely in 2027.

What This Means for Businesses:

• Test pricing strategies and margin resilience to prepare for potential VAT increases.
• Review contracts with VAT clauses, especially for fixed-price agreements, long-term services, and subscription models.
• Prepare systems and tax codes for different VAT scenarios.
• Proactively inform customers and partners about potential changes.

Key Takeaway: Start scenario planning now to avoid surprises and ensure readiness for the next VAT adjustment.

Planned Amendments to the VAT Act (earliest implementation in 2029):

• Expansion of platform taxation to include electronic services (Motion WAK-S 23.3012).
• Adjustments to the taxation of service combinations (Motion Engler 18.3235).

Extension of the Special Rate for Accommodation Services (implementation 2028):

• Federal Council proposes an extension after 2027 until the end of 2035 (Motion Friedli 24.3635).

What is changing?

• The current e-dec import system is being replaced by Passar 2.0.
• This affects payment processes and document downloads. Current systems can no longer be used with Passar 2.0, requiring measures.
• If a company does not register and assign the necessary roles in advance, there is a risk of incomplete archiving of customs documents.
• Timeline: Passar 2.0 is expected for launch in late summer or autumn 2026, with a transition period where Passar 2.0 and e-dec Import are running in parallel until 31 March 2027. However, a detailed timeline has not yet been published and the end date of e-dec Import is currently under discussion. Despite that, the decisive date for each company is when their customs broker (declarant) switches to Passar 2.0.

What do companies need to do?

• Businesses shall create an account in the government’s ePortal and register their company as business partner of the FOCBS in the application Connex, assigning the appropriate roles.
• Since the system used by the customs brokers is decisive, they should be contacted to find out when they will be switching to Passar 2.0.
• To be compliant with archiving requirements and avoid gaps, businesses should review their internal processes and ensure all necessary customs documents are downloaded from the Customs Client Administration system to the company's internal servers.
• In preparation of the new download and payment processes, internal guidelines and processes should be updated and once the new ePortal application Finanzas is live, companies shall check their debtor status (red/green), which is necessary to pay import duties in Passar 2.0.

Good to know

• ZAZ accounts can still be opened and are still needed for customs declarations in e-dec Import.
• Documents from e-dec will continue to be available in the Customs Client Administration system, and no shutdown has been announced yet. Nevertheless, we recommend downloading these documents to comply with archiving requirements and to be prepared in case of a VAT audit.
• The FOCBS has issued a call to action via email and its website, but several key details remain pending.
• The new debtor status is assigned automatically based on the assigned role. Companies must verify their red/green status in the ePortal via Finanzas once it becomes available (expected in summer 2026).

The Switzerland–EU package “Bilaterals III” aims to stabilise and further develop relations by updating existing single market agreements and adding new ones on electricity, food safety, and health, alongside rules on state aid, participation in EU programmes, a Swiss cohesion contribution, and new political and parliamentary dialogues.

The broad package of bilateral agreements includes wide range of elements such as updates to agreements giving access Switzerland to the internal market, agreement on trade in agricultural products or agreements on food safety, health and electricity.

Key timeline milestones: negotiations launched in March 2024 and concluded in substance in December 2024; agreements initialled in May 2025; the Council of the EU authorised signature on 24 February 2026; the agreements were signed on 2 March 2026; and the Federal Council submitted the dispatch to Parliament on 13 March 2026, opening the parliamentary phase.

Legislative scope and domestic measures: the package ties to 94 EU legal acts, creates three new Swiss federal laws (state aid monitoring; administrative cooperation on recognition of professional qualifications; Swiss contributions to European cohesion), amends 36 federal laws, provides four commitment appropriations, and is slated for an optional treaty referendum.

What happened?

• The EU pharmaceutical reform has reached an advanced and largely settled stage, with substantive changes now considered highly unlikely
• Article 166(1)(c) of the new Pharmaceutical Directive explicitly brings financial transactions into the scope of wholesale distribution rules
• Wholesale distribution authorisation holders must procure their supplies, "including by financial transactions," only from entities holding an EU/EEA wholesale or manufacturing authorisation
• Arrangements where products are physically stored in the EU/EEA but invoiced or sold by a non-EU/EEA entity without the appropriate authorisation are expected to be incompatible with the new framework

This builds on years of enforcement and case law

• Germany (2021): The Federal Administrative Court ruled that controlling the supply chain, including financial transactions, is what matters, not merely the physical flow of goods
• CJEU (2023): Confirmed that wholesalers must source exclusively from authorised suppliers within the EU/EEA
• Sweden (2025): The Administrative Court of Appeal affirmed that procuring from a non-EU/EEA entity is non-compliant
• What was established through individual rulings is now written into harmonised EU/EEA legislation

Who is affected?

• Any non-EU/EEA-based pharmaceutical company that sells or invoices EU-stored medicinal products to EU/EEA wholesalers or group affiliates
• This includes companies operating under a Swiss principal model
• Health authorities across Member States are already challenging such arrangements during GDP inspections
• Non-compliance can result in major findings or supply chain disruptions

Why you should not wait

• The transitional period to 2028 relates to formal transposition into national law, but it does not pause current enforcement
• Health authorities are already applying the underlying principles today under existing GDP requirements and established case law
• Redesigning an operating model of this nature typically takes up to 12 months and spans regulatory, tax, transfer pricing, operations, finance, and IT workstreams
• Companies that treat 2028 as a distant deadline risk finding themselves on the wrong side of an inspection before the Directive formally applies

The good news: solutions exist

• This is not an existential threat to Swiss-based pharmaceutical headquarters
• What must change is not necessarily where strategic decisions are made, but how commercial and financial flows are structured
• Practical, compliant solutions can preserve the strategic and economic benefits of a Swiss centre while fully satisfying EU/EEA regulatory expectations
• Success depends on addressing regulatory compliance, tax, transfer pricing, and operational feasibility as one integrated equation from the start

Read the full blog post here

Overview: The Zurich cantonal tax administration is moving away from treating distribution in asset management as a routine function remunerated on a cost-plus basis, shifting instead toward an entrepreneurial function classification.

Details: Distribution in asset management will be treated as an entrepreneurial function by default, which in practice points to profit allocation via a revenue or profit split rather than a cost-based method. Existing cost-plus rulings may no longer be extended and could be withdrawn in certain cases, meaning historical “routine distributor” positions are becoming harder to sustain. Market commentators anticipate that other cantons may follow Zurich’s lead in adopting this approach, which would mark a broader shift in the Swiss transfer pricing landscape for the asset management sector. This trend is consistent with the wider international emphasis — reflected in the OECD Transfer Pricing Guidelines — on aligning profit allocation with the functions performed, assets used, and risks assumed, particularly where distribution activities involve significant client relationship management, regulatory engagement, and market development.

Practical Implications: Asset management groups with Swiss distribution entities should proactively reassess their transfer pricing models. In particular, existing cost-plus arrangements should be reviewed for sustainability, and groups should consider whether a profit split or other profit-based method better reflects the economic substance of the distribution function. It is important to verify the tax authorities’ current position during any ruling request or audit process, as practices may vary by canton. We will provide updates on the practical approaches we encounter as they become available.

Overview: The amendment protocol to the double tax treaty (DTA) between Germany and Switzerland introduces new rules for mutual agreement and arbitration procedures, effective from 1 January 2026.

Details: The protocol modernises the dispute resolution framework under the Germany–Switzerland DTA, introducing updated procedural rules for mutual agreement procedures (MAP) and, notably, arbitration provisions. These changes aim to provide greater certainty and more effective relief from double taxation for cross-border transactions between the two countries.

Practical Implications: Swiss-headquartered groups with significant German operations should familiarise themselves with the revised MAP and arbitration framework, as it may offer improved avenues for resolving transfer pricing disputes with Germany — one of Switzerland’s most important trading partners.

For further details, see the PwC Transfer Pricing Perspectives DACH article

Overview: The OECD has published the 2026 edition of its Manual on Effective Mutual Agreement Procedures (MEMAP), a key reference guide for MAP and arbitration, thoroughly updating the 2007 version.

Details: Released on 2 February 2026, the MEMAP incorporates 59 best practices and hands-on templates developed by competent authorities from the FTA MAP Forum, drawing on over a decade of experience and peer reviews from BEPS Action 14. The manual covers the full MAP lifecycle, including arbitration, and is designed to improve the quality and consistency of dispute resolution processes across jurisdictions.

Practical Implications: Multinationals involved in or anticipating cross-border tax disputes — particularly those with Swiss headquarters engaging competent authorities — should familiarise themselves with the updated best practices and templates, which can help structure MAP requests and set realistic expectations for the resolution process.

For further details, see the OECD publication

Overview: The OECD has published the fourth and final batch of updated Transfer Pricing Country Profiles in January 2026, covering eight additional jurisdictions and adding new content areas relevant to multinational groups.

Details: The January 2026 update covers eight jurisdictions, including several in Europe (e.g., Croatia, Greece, Norway, Bosnia & Herzegovina, Iceland), and adds or refines content areas such as hard-to-value intangibles and the simplified approach for baseline marketing and distribution (Amount B-related content).

Practical Implications: Multinationals operating in the updated jurisdictions should re-check the refreshed country-profile expectations. For groups that intend to roll out Amount B approaches, the updated profiles can be used as a practical “jurisdiction check” to assess local implementation.

For further details, see the OECD page

Overview: Switzerland is introducing new location development measures aimed at fostering innovative and sustainable companies, which may have implications for transfer pricing structures and incentive arrangements.

Details: The new measures are designed to enhance Switzerland’s attractiveness as a business location by supporting companies engaged in innovation and sustainability. These incentives may affect the functional and risk profiles of Swiss entities within multinational groups, with potential transfer pricing implications for the allocation of profits to Swiss operations.

Practical Implications: Companies should conduct a thorough segmentation of their income statements to identify R&D and DEMPE-related (in a broad sense) personnel expenses, engaging accounting departments and auditors well in advance of the 31 May filing deadline. Any ambiguities in determining the qualifying cost base should be clarified with the Zug authorities promptly, and companies must verify that their activities are not already funded through comparable government programmes elsewhere.   For the sustainability component, companies should assess whether they meet the 50,000 tonne CO₂-equivalent threshold and prepare a complete GHG inventory with assurance from a state-supervised audit firm. Groups must review their transfer pricing structures for consistency, ensuring that the allocation of innovation functions and DEMPE-related personnel to Swiss entities is reflected in updated intercompany agreements, transfer pricing documentation and defence files.

For further details, see the PwC Transfer Pricing Perspectives DACH article

Overview: The Swiss Federal Tax Administration (SFTA) has published the annually recognised interest rates for advances and loans in CHF and foreign currencies for 2026, relevant for both direct federal tax and withholding tax contexts.

Details: Swiss safe-harbour interest rates are generally accepted by Swiss tax authorities for domestic intercompany loans, providing legal certainty and reducing administrative burden. However, they are not automatically acceptable for cross-border transactions, where foreign tax authorities may challenge them, requiring an arm’s-length, market-based transfer pricing analysis to justify the rate.

Practical Implications: Swiss-headquartered groups should update intercompany loan agreements and TP documentation to reflect the 2026 rates. For cross-border financing, a standalone benchmarking analysis remains essential.

For further details, see the PwC blog post

The EU and Australia public Country-by-Country reporting (CbCR) frameworks are no longer a distant prospect - it's a present reality. Spain has already implemented earlier reporting obligations deadline as of June 2026, with the rest of the EU Member States and Australia following later in the year.

Swiss-based multinational enterprises (MNEs) are not off the hook. Non-EU parent companies with subsidiaries or branches in EU Member States might be subject to the EU public CbCR - and possibly the Australian public CbCR - even if they haven't yet reached the thresholds for OECD CbCR.

Key points to consider:

• Jurisdiction-specific compliance requirements: Compliance requirements vary across EU Member States and Australia and these requirements are continually evolving.
• Public CbCR disclosure goes beyond compliance: It's not just about ticking boxes; your data will be scrutinized by investors, the media, tax authorities, competitors and other external stakeholders.
• Interconnection with Pillar Two & OECD CbCR: Differences between publicly disclosed public CbCR data and the figures used in Pillar Two Transitional Safe Harbour calculations or OECD CbCR can pose compliance and reputational  risks.
• Data quality and governance: Transparency demands that your data is reliable, accurate, and consistent, with any differences clearly explained.

We advise Swiss-based MNEs to promptly evaluate which public CbCR obligations apply to them, align key deadlines, and perform a data dry-run to uncover potential risks before making disclosures public.

Our team at PwC Switzerland is ready to assist you with a comprehensive five-step approach that includes scope and impact assessments based on compliance requirements, data cleansing and governance, risk and dry-run review, narrative preparation, and tech-enabled filing support.

Explore our PwC’s EU public CbCR Tracker for more insights (link).