Tax Newsletter Switzerland

During its meeting on 24 June 2026, the Federal Council adopted the dispatch on the Protocol of Amendment to the Agreement between Switzerland and the European Union (EU) on the automatic exchange of financial account information to improve international tax compliance. The Agreement will be aligned with the revised OECD standard and also contains new provisions on administrative assistance for the recovery of VAT claims. The overwhelming majority of consultation participants agree with the proposal. For more information, see the following link.

On 29 April 2026, a new mutual agreement between Switzerland and France concerning the taxation of cross-border hybrid-work was concluded. This mutual agreement is based on the provisions of the supplementary agreement dated 27 June 2023 to the double taxation treaty, which entered into force on 24 July 2025 and has been applicable since 1 January 2026. The mutual agreement corresponds in content to that of 30 June 2023 but refers to the new legal framework. The information sheet with examples has also been adapted to the new legal framework. 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.

To reduce the administrative burden on taxpayers, the Swiss Federal Tax Administration (SFTA) abolished the requirement to file the official form (Form 9 / Form 9 FL) for the securities transfer tax when no tax is due for the relevant period.

The publication can be found under the following link.

On 19 December 2025, the Swiss Parliament adopted an extension of the tax loss carry-forward period from 7 to 10 years. The new period applies to losses incurred from the 2020 tax period onwards, including COVID-19-affected years, while earlier losses remain subject to the 7-year limit. The referendum period lapsed unused on 17 April 2026. The Federal Council will take the actions to finally enact this change in due time.

The legal text adopted by the Swiss Parliament is available at the following link.

The Federal Council launched consultations on tax simplifications as part of a broader package to ease regulation for Swiss businesses. Proposed changes:

• VAT: All companies, regardless of turnover, would be able to opt to file VAT returns annually instead of quarterly (previously limited to firms with turnover up to ~CHF 5m).
• Withholding tax & issuance stamp duty – financial statement submissions: Businesses would only need to submit annual financial statements without being asked if they distribute a dividend or deemed dividend (withholding tax) or upon request by the Federal Tax Administration (issuance stamp duty). The current mandatory filing threshold (balance sheet > CHF 5 million) would be eliminated.
• Withholding tax – expanded notification procedure: Notification procedure would be extended to further intra-group relationships (beyond parent-subsidiary).
• Restructurings: Easier exemption from issuance stamp duty – the application requirement and the CHF 10m cap on shareholder contributions would be abolished.

Further information is available at the following link.

The Federal Council adopted a report on Switzerland's long-term tax and location strategy. It confirms a solid foundation, but identifies action needs given international, demographic and technological developments. The focus is on corporate taxation following the OECD/G20 minimum tax. A working group with the cantons will examine options to strengthen location attractiveness, with initial results expected by early 2027 and further steps to be decided in the first half of 2027. Any changes should be integrated into the future minimum-tax legislation. The report also notes potential simplifications for income and consumption taxes.

Further information is available at the following link.

The new SFTA portal is available since May 2026. This portal combines various SFTA online services in one place. The SFTA is gradually migrating the online services to the new SFTA portal.

Further information is available at the following link.

On 6 May 2026, the Federal Council opened a consultation on amending the Minimum Taxation Ordinance, implementing two parliamentary motions. These require an OECD administrative guideline – governing how pre-existing deferred tax assets are treated when calculating the effective tax rate – to be applied in Switzerland only from the 2025 financial year, rather than from 2024 as internationally foreseen. The consultation ran until 14 July 2026, with entry into force planned immediately after the Federal Council's decision.

Further information is available at the following link.

On April 7, 2026, the Swiss Federal Tax Administration published two communications in relation to the Swiss top-up tax (Pillar Two).

1. Introduction of New Safe Harbour Rules: On 5 January 2026, the OECD/G20 Inclusive Framework introduced the "Side-by-Side Package" with five new safe harbour rules, which are now applicable in Switzerland according to the Swiss Minimum Taxation Ordinance. These rules include the extension of the Transitional CbCR Safe Harbour, the Substance-based Tax Incentive Safe Harbour, and others, aimed at simplifying compliance by minimizing the need for full GloBE calculations. They apply to fiscal years beginning from various dates in 2025 and 2026, contingent on meeting specific conditions.
2. Clarification on Administrative Guidance for Article 9.1 on Deferred Tax Assets: The guidance regarding Article 9.1, effective 13 January 2025, specifies exclusions for deferred tax expenses from the ETR calculation tied to certain deferred tax assets, with a "Grace Period" and "Grace Period Limitation" of 20% cap on the original DTA balance. Swiss Parliament's prospective amendment to the ordinance was discussed, and meanwhile, the interim guidance requires timely filing based on current rules, with the inclusion of remarks about ETR reduction due to the Grace Period Limitation in tax returns. Cantonal tax authorities are advised to delay final tax assessments until amendments are confirmed.

These developments could impact filing strategies and compliance obligations for groups subject to the Swiss top-up tax. For more detailed insights, you may need to refer to the official communications or seek legal advice.Top of FormBottom of Form

Further information is available at the following link.

The withholding tax exemption for too-big-to-fail instruments has been extended again, ensuring Swiss banks can continue issuing such instruments under competitive conditions and supporting financial stability.

Further information is available at the following link.

The dossier tax information “applicable taxes” has been updated.

The dossier can be found under the following link.

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

The overviews can be found under the following link.

The Federal Tax Administration has updated the course listings and bonus shares 2024, 2025 and 2026.

The lists can be found at the following link.

The dossier tax information “taxation of legal entities” has been updated.

The dossier can be found under the following link.

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

• SFC dated 10 April 2026: The Federal Supreme Court addressed a tax dispute where Solothurn's Tax Office reclassified a shareholder's loan as a simulated loan when the shareholder moved to Germany in 2021. Initially, only the increases in the loan were taxed as simulated, but in 2021, the entire "base amount" was included in taxable income. The Court determined that the "base loan" conditions for simulation were apparent by the end of 2018, thus it should not be taxed in 2021. Only the 2021 loan increase of CHF 488,249 is to be included in that year's taxable income. The decision necessitates recalculating the taxable amount, excluding the base loan.
• SFC dated 22 April 2026: The Federal Supreme Court ruled on a dispute involving a family-owned company's shareholder agreement, which allowed share transfer at nominal value upon withdrawal or death. Vaud tax authorities taxed the nominal-to-tax value difference as a mixed donation, imposing gift tax and penalties. However, the Court emphasized the timing of the 2008 agreement, which symmetrically applied to all shareholders, negating the presumption of a gift intent (animus donandi) in the 2017 transfer. The Court found no conclusive evidence of intent to gift at the transfer’s execution, overturning the cantonal ruling and voiding related tax and penalties. 
• SFC dated 2 June 2026: The Federal Supreme Court upheld an appeal concerning securities transfer tax on transactions by a Liechtenstein single-investor fund. The lower court had held that foreign collective investment schemes under Art. 119 KAG must satisfy the same requirements as domestic schemes under Art. 7 KAG, which restrict single-investor funds to qualified investors. The Federal Supreme Court disagreed: in particular, the legislative history shows a deliberately broader concept for foreign schemes. Where a foreign supervisory authority (here Liechtenstein) accepts a single-investor fund, this suffices. The fund is therefore an exempt investor under Art. 17a(1)(c) StG.
• SFC dated 9 June 2026: The Federal Supreme Court confirmed that the taxpayer in this case was subject to tax in the Canton of Zurich (at the domicile of its sole shareholder), rather than at its statutory seat in Zug, since the place of effective management was located in the Canton of Zurich. At the same time, the Court clarified that in intercantonal double-taxation appeals, a subsidiary claim against the other canton (here, Zug) must be filed explicitly and within the appeal deadline – a merely "unidirectional" claim against only one canton is no longer sufficient to fully prevent a threatened double taxation.

The Canton of Zurich's tax office published guidelines on international tax allocation for properties, businesses, and permanent establishments, detailing procedures for avoiding inter-cantonal and international double taxation. Additionally, the guidelines address changes in practice concerning indirect partial liquidation, aligning Zurich's approach with the Swiss Federal Tax Administration following the Swiss Federal Court's decision, particularly in determining the timing and treatment of distributable accounting reserves.

For more information, visit the official link.

Introduction of the new Federal Act on the Transparency of Legal Entities and the Identification of Beneficial Owners (TJPG): The new act will come into force on 1 October 2026 and it will apply to all Swiss stock corporations, limited liability companies, and most other Swiss incorporated entities. Foreign entities are also in scope where they have registered Swiss branches, own or acquire real estate in Switzerland, or have their de facto administration located in Switzerland. Exempted are, among others, listed companies and entities in which a listed company directly or indirectly holds more than 75% of the shares, sole proprietorships, associations, and foundations.

What needs to be done: Affected entities must actively report their beneficial owner(s) to a centralised transparency register managed by the Federal Office of Justice and keep the reported information up to date. The deadlines for reporting are rather short, so early preparation is key. If no beneficial owner can be identified, the most senior member of management must be reported instead. The information to be reported includes name, date of birth, nationality, country and city of residence of the UBO, and the manner in which control is exercised. Intentional violations of the reporting obligations by companies, shareholders and beneficial owners are subject to fines of up to CHF 500,000. 

Further information is available at the following link.

The EU Commission, following the publication of the strategy for the implementation of VAT in the Digital Age (ViDA), has released the relevant working programme which serves as a reminder of the parts constituting ViDA and the steps the Commission is taking to implement them within 2026/2027.

Key dates:

• Current status: After the proposal’s adoption and publication in the Official Journal of the European Union, Member States may introduce mandatory e-invoicing under certain conditions, and Import One Stop Shop (IOSS) controls are strengthened. Member States such as the Netherlands and Poland have started the legislative process.
• Q2 2026: Publication of the EU e-invoicing standard; adoption of the first amendment to Implementing Regulation (EU) 2020/194. The e-invoicing standard has already been approved.
• Q3 - Q4 2026: Adoption of Implementing Regulation on the transmission of data between MS and central VIES, plus ensuring IOSS numbers will not be misused.
• Q1 2027: Second Implementing Regulations on central VIES and One Stop Shop (OSS) SAF-T file.
• From 1 January 2027: OSS/IOSS clarifications take effect.
• From 1 July 2028: Deemed supplier rules for platforms and Single VAT Registration measures apply (platform rules deferrable to 1 January 2030).
• From 1 July 2030: Digital Reporting Requirements for cross-border B2B supplies apply.
• By 1 January 2035: Deadline to align domestic real-time reporting with the EU system.

On the Digital Reporting Requirements - where we expect the geatest impact for companies required to implement EU e-invoicing - the Euripean Commission will discuss the Explanatory Notes in June and November this year. The notes are expected to be made public following the November discussion.

If you need to discuss the implications and opportunities the implementation of ViDA may bring to your business, please reach out to the experts listed at the bottom of this page.

On 30 March 2026, the European Committee for Standardisation (CEN) announced the approval of the revised European e-invoicing standard, now referenced as EN 16931-1:2026. This standard sets out the semantic data model, essentially the common language and structure that electronic invoices must follow across the European Union. 

If you need to discuss e-invoicing in Europe, do not hesitate to reach out to our experts listed at the bottom of this page. 

Spain has published the Royal Decree formalising its mandatory B2B e-invoicing system. The decree establishes technical standards, platform obligations, and transitional measures for businesses and professionals.

The effective application of the Decree’s substantive obligations is conditional on the entry into force of a separate ministerial order from the Ministry of Finance, which will set out the technical specifications of the public e-invoicing platform. Once the ministerial order enters into force, the following phased deadlines will apply:

• 12 months: corporate e-invoicing platforms must meet the specific interconnection and reporting obligations set out in the decree.
• 12 months: businesses and professionals whose turnover exceeded EUR 8 million in the immediately preceding calendar year must begin issuing and receiving e-invoices. During this initial twelve-month period, e-invoices must be accompanied by a PDF document to ensure legibility for recipients not yet subject to the obligation.
• 24 months: all remaining businesses and professionals must comply. 
• 36 months: the obligation to report invoice statuses (acceptance, rejection, and payment information) is deferred for individuals (personas físicas) and entities under the régimen de atribución de rentas (tax-transparent income allocation regime partnerships and similar entities whose income is attributed directly to their members for tax purposes).

On 31 March 2026, the Italian tax authorities provided clarifications regarding the recovery of VAT on amounts due as payback on medical devices.

Pending communications from the Regions and Autonomous Provinces, the supplying companies of medical devices, holding the sales invoices relating to medical devices, may determine recoverable VAT analytically by allocating turnover by VAT rate for each year (2015-2018) and for each Region or Autonomous Province.

To exercise the right to VAT deduction, the supplying companies of medical devices are required to issue an internal adjustment credit note, specifying the regional and provincial measures, sequential numbers of the corrected invoices, and taxable base and VAT separately for each rate. The credit note does not need to be transmitted to the Exchange System (so called “Sistema di Interscambio”) and must be recorded in the relevant periodic settlement and reported in the annual VAT return.

For companies that made the reduced 25% payback by 9 September 2025 (Article 7, Law Decree No. 95/2025), the credit note must be issued by 30 April 2026. Given this tight deadline and the burden of reconstructing historical turnover data, companies should act promptly to secure their right to VAT deduction.

On 31 March 2026, the Italian Tax Authorities published the new Technical Specifications for electronic invoicing, effective 15 May 2026.

Main changes introduced:

• A new validation check by the Exchange System (“SdI”) (error code 00327) has been introduced on the e-invoices within VAT Groups. The system will now reject an invoice where the VAT Group's VAT number is missing from the transferee/client field and the Group's tax code (rather than the individual participating entity's tax code) is entered in the tax code field of the transferee/client.
• A new coding ("ESENZSPORT") has been introduced in the respective block to identify income invoiced by amateur sports workers under the tax-exempt regime (up to €15,000 per year), enabling automatic regime identification by the SdI.

Businesses issuing or receiving electronic invoices in Italy should review the updated specifications and assess any impact on their invoicing processes, system configurations, and transmission channels to ensure compliance.

The French tax authority has clarified that foreign businesses without a permanent establishment in France may still be subject to e-reporting where they carry out transactions liable to French VAT.

Mandatory e-invoicing (issuing and receiving structured electronic invoices) applies only to domestic B2B transactions between VAT-taxable persons established in France; non-established entities instead face e-reporting, which means sending the tax authority transaction details, such as the transaction amount and the VAT charged, for sales not covered by e-invoicing.

Foreign companies without a French permanent establishment must e-report where they are liable for French VAT. In-scope transactions may include certain supplies of goods or services deemed to take place in France, non-exempt intra-Community acquisitions in France, and B2C sales liable to French VAT, unless covered by the EU VAT One Stop Shop.

Certain transactions are excluded, including exports, intra-Community supplies, VAT-exempt transactions and imports.

The rules will be phased in from 1 September 2026 for large and intermediate-sized enterprises, and from 1 September 2027 for smaller businesses and certain buyers liable for VAT.

Businesses potentially in scope should assess their French VAT footprint and select an authorised reporting platform ahead of the applicable go-live date.

• Regulation (EU) 2026/1384, generally applicable from 1 July 2026, establishes a permanent protective framework for the EU steel sector, replacing and substantially tightening previous safeguard measures. It introduces annual tariff quotas across 28 steel product categories (totalling approximately 18.3 million tonnes), allocated on the basis of 2022–2024 import shares and administered on a quarterly basis with automatic carry-over of unused volumes. The out-of-quota ad valorem customs duty is doubled from 25% to 50%, levied in addition to any other applicable duties, significantly increasing cost exposure for importers unable to secure quota allocations. Imports from EEA states (Iceland, Liechtenstein and Norway) are exempt from both the quotas and the out-of-quota duty.
• From 1 October 2026, a new stand-alone obligation requires importers to provide evidence of the country of "melting and pouring" - i.e. where crude steel or pig iron was first produced in liquid form and cast into its first solid state - shifting the determining factor beyond non-preferential origin. Evidence must be furnished at the time of import (e.g. by way of a mill certificate), with detailed implementing arrangements to be adopted by 31 August 2026. From 1 October 2027, this data will additionally be factored into country-specific quota allocations.
• Steel importers should now review supply chains, sourcing arrangements and documentation processes to ensure early compliance with the tightened quota regime, the elevated out-of-quota duty rate and the new evidentiary requirements. Country-specific quota allocations will be determined by implementing acts yet to be adopted, using 2013 import market shares as a baseline and taking into account factors such as existing and future free trade agreements and supply diversification needs. Failure to adapt promptly risks materially higher duty exposure and potential supply disruptions.

• On 16 June 2026, the European Parliament gave its final approval to two regulations implementing the tariff-related elements of the August 2025 EU–US "Turnberry agreement". The main regulation eliminates tariffs on all US industrial goods and grants preferential market access for a wide range of US seafood and agricultural products; the second regulation extends duty-free imports of lobster, now including processed lobster. Both texts proceed to the Council for formal adoption and will enter into force the day after publication in the Official Journal.
• Parliament secured several strengthened safeguard mechanisms during the legislative process. Notably, the Commission may suspend tariff preferences if, by 31 December 2026, the US continues to apply tariffs above 15% on EU steel and aluminium derivatives, with a report due by 1 December 2026. A broader suspension clause allows preferences to be withdrawn where the US fails to address EU concerns over the tariff treatment of Union exports that previously benefited from the 15% all-inclusive ceiling. In addition, a safeguard mechanism empowers the Commission to investigate import surges threatening serious injury to EU industry or agriculture, supported by quarterly reporting on US export volumes and values.
• The main regulation includes a sunset clause, expiring on 31 December 2029 unless renewed, with a full impact assessment due by 30 June 2029. Businesses trading across the Atlantic should monitor the implementing measures closely - particularly the December 2026 steel and aluminium review - to assess the durability of the new preferential terms and adjust sourcing and compliance arrangements accordingly.

• On 2 June 2026, the European Commission adopted Implementing Regulation (EU) 2026/1183, amending Implementing Regulation (EU) 2015/2447 to overhaul the procedural rules governing the preferential origin of goods. The reform pursues two parallel objectives: the gradual dematerialisation of proofs of origin and the reinforcement of documentary controls across supply chains. Key changes include the introduction of the EU e-PoC system for the electronic issuance, exchange and verification of origin certificates- mandatory under the PEM Convention from 26 June 2030 for certificate applications and from 23 June 2032 for electronic exchange with Contracting Parties - as well as a consolidation of the REX system, updated definitions of core concepts (e.g. "document on origin", "preferential agreement") and a streamlined verification procedure that removes the distinction between reasonable-doubt and random requests in favour of risk-based assessment. The Regulation generally applies from 23 December 2027, with certain provisions (including those on definitions, supplier declarations and the deletion of specified Annexes) deferred to 23 June 2028.
• Supplier declarations are subject to significant new requirements: they may now cover multiple shipments of identical goods and be transmitted electronically, but must follow standardised data fields set out in the Regulation. Administrative cooperation between Member States is strengthened, with a 120-day deadline for customs authorities to respond to verification requests - failing which the supplier's declaration will be disregarded. For companies with complex, multi-supplier supply chains, this means that a lack of cooperation or insufficient documentation at any point upstream could jeopardize the preferential origin of goods further down the chain. Exporters already registered in the REX system must include their REX number on all documents on origin regardless of consignment value, and three-year record-keeping obligations apply.
• Operators should treat this reform as more than a technical reorganisation: it signals a deeper transformation in how preferential origin is managed and enforced. Practical steps include updating internal origin procedures and document templates, reviewing REX registration and the €6,000 threshold conditions, adapting supplier declaration formats to the new standardised requirements, and preparing for the phased roll-out of the e-PoC system. Companies relying on inward processing or GSP arrangements should pay particular attention to traceability and documentary completeness, as the capacity to demonstrate the reliability of the entire document chain in the event of an audit is becoming a core compliance expectation.

• The EU introduced a temporary €3 customs duty per item on low-value consignments (up to €150) imported from outside the EU, replacing the previous duty-free "de minimis" exemption.
• The flat fee applies from 1 July 2026 until 1 July 2028, after which normal customs tariffs will take effect.
• Scope: Covers distance sales (e.g., online purchases from non-EU suppliers), regardless of VAT scheme (IOSS, Special Arrangements, or standard VAT). Goods under preferential trade agreements or Customs Union measures may be excluded.
• Calculation: The €3 fee is charged per item by tariff classification, not per parcel or per unit quantity.
• Purpose: Part of the EU's Customs Reform to level the playing field between non-EU e-commerce sellers and EU retailers, addressing the exponential growth in low-value imports (~5.9 billion items in 2025).
• Not a consumer tax: The duty replaces an outdated exemption that gave certain business models an unfair competitive advantage.
• Union handling fee: A separate fee to cover customs processing costs is proposed, with details to be confirmed in autumn 2026.
• Product Identifiers (PIDs): Voluntary from 1 July 2026; mandatory from 1 November 2026 to improve traceability and safety.

• The EU - Mercosur Interim Trade Agreement (ITA) began provisional application on 1 May 2026, per a European Commission announcement dated 30 April 2026, covering trade with Argentina, Brazil, Paraguay, and Uruguay.
• Tariffs on key exports such as cars and pharmaceuticals are immediately cut or removed, with a first tariff cut also applying to most agri-food products like wine, spirits, and olive oil.
• EU companies can now bid on Mercosur public and government contracts on equal footing with local firms, thanks to simpler, more transparent tendering rules and reduced domestic preferences.
• Services exporters benefit from new licensing rules and non-discriminatory procedures, while elimination of non-tariff and technical trade barriers (conformity assessment, labelling, standards) begins. 
• EU agri-food exports to Mercosur are projected to rise 50%, supported by initial tariff-rate quota access and protection of 344 EU Geographical Indications against imitation.
• Provisional application follows a January 2026 European Council decision and President von der Leyen's 27 February 2026 confirmation, and includes safeguards (calibrated quotas, a safeguard mechanism, enhanced controls) to protect sensitive EU agri-food sectors. 

• On 3 June 2026, President Trump signed an executive order titled "Strengthening Customs Enforcement," which overhauls the importer of record (IOR) framework by sharply restricting foreign IORs' ability to file entries into the United States, imposing new bonding, beneficial-ownership disclosure, and CTPAT validation requirements, and introducing a "good standing" standard for all importers - with key implementation deadlines falling at 90 and 180 days.
• The order establishes a significantly higher penalty floor of no less than 50% of the assessed penalty, eliminates mitigation for repeat offenders, and directs maximum penalties against customs brokers who fail to conduct due diligence or repeatedly represent non-compliant clients - fundamentally altering the risk calculus around voluntary disclosures and prior-disclosure strategies.
• Importers to the US - particularly foreign entities and those relying on informal entry channels - should urgently review their US presence, bonding arrangements, and compliance programmes, as the order contains no country-specific exemptions and creates a narrow but real window to prepare before the new requirements take effect.

• Effective dates and legal basis: The June 1, 2026 proclamation amends Proclamation 11021 (April 2, 2026), which itself modified the Section 232 national security tariff regimes on aluminium, steel, and copper established under Proclamations 9704, 9705, and 10962; most changes take effect for goods entered on or after 12:01 a.m. EDT, June 8, 2026, with a further rate transition on January 1, 2028.
• Expanded coverage for equipment used in production: Agricultural equipment and certain residential HVAC systems and components are added to the category eligible for the temporarily reduced 15 percent ad valorem duty, and mobile industrial equipment and machinery receive a temporary (unspecified rate) modification, both intended to support US businesses using these products.
• New products brought within tariff scope: Aluminium lithographic plates and steel racks, previously untaxed under the metals tariff regimes, are now classified as covered derivative products subject to the applicable Proclamation 11021 duty, closing a perceived circumvention gap.
• Lower domestic-content threshold: The standard for a product to qualify as made "entirely" of American aluminium, steel, or copper is reduced from 95 percent to 85 percent by weight, intended to incentivize greater (but not exclusive) use of domestic metal in derivative products.
• Tiered duty structure (June 8, 2026–December 31, 2027): A 25 percent general backstop rate applies to Annex I-C aluminium and steel articles, with exceptions: named partners (including Japan, South Korea, the UK, Switzerland, and EU members) get a rate that tops up their existing Column 1 duty to 15 percent (or zero if already at/above 15 percent); products entirely of qualifying US-smelted/melted metal get 10 percent; and USMCA-qualifying Canadian/Mexican goods pay 25 percent only on non-US content, subject to a 15 percent effective-duty floor.
• Implementation and enforcement: The Secretary of Commerce, in consultation with USTR, the ITC Chair, and DHS, will issue Federal Register notices to update the HTSUS and CBP guidance on assessing "US content," while Commerce, DHS, and USTR are authorized to take all actions needed to implement and enforce the proclamation.

• On June 2, 2026, United States Trade Representative (USTR) determined under Section 301 of the Trade Act of 1974 that 60 economies' failure to impose and effectively enforce a prohibition on importing forced-labour-produced goods is unreasonable, burdens US commerce, and is therefore actionable, following investigations self-initiated on March 12, 2026.
• Of the 60 economies, 54 - including China, India, Japan, Brazil, Russia, Saudi Arabia, South Korea, Switzerland, the United Kingdom, and Vietnam among others - were found to have failed both to impose and to effectively enforce a forced-labour import ban, while six others (Canada, Ecuador, the European Union, Indonesia, Mexico, and Pakistan) were found to have failed specifically at effective enforcement of an existing ban.
• USTR reasoned that these failures are unreasonable because they undermine the global goal of eliminating forced labour, let forced-labour-using firms undercut compliant competitors on cost, and enable circumvention of existing import prohibitions, while also burdening US commerce by exposing US producers to unfair competition and displacing legitimately produced goods.
• As proposed remedies, USTR recommends additional duties on nearly all products from the 60 economies (with exceptions in Annex A): a 10% rate for economies that already impose a forced-labour import ban, have committed to one via an Agreement on Reciprocal Trade, or have a partial preventive regime, and a 12.5% rate for all other economies, plus a textile mechanism allowing a set volume of apparel/textile imports from certain economies at a reduced tariff rate.
• Key procedural deadlines are requests to testify at hearings due June 22, 2026, written comments on the proposed action due July 6, 2026, and public hearings scheduled for July 7, 2026, with supporting materials available via USTR's report, the June 5, 2026 Federal Register notice, and public comment dockets.

On 1 January 2026, the European Union’s (EU) Carbon Border Adjustment Mechanism (CBAM) entered fully into force, covering 569 products of aluminium, cement, electricity, fertilisers, iron and steel, and hydrogen. The European Commission proposes to extend the CBAM-product list to 749 from 1 January 2028 onwards. As required in the EU ordinary legislative procedure, the Council of the European Union (12 June 2026) and the responsible committee in the European Parliament (6 July 2026) have also published their respective positions on the extension of the list of CBAM-products for 2028. The Council proposes to extend the scope of CBAM to 946 products and the Parliament proposes to extend the list to 1032 products. The final product list will be decided in the trilogue negotiations later this year. What is clear already is that CBAM is moving further downstream and will apply to products in machinery, mechanical appliances, precision measurement, and others.

Due diligence is rapidly becoming a core business requirement across the EU regulatory landscape. With new and evolving regulations placing greater emphasis on supply chain transparency, human rights, environmental impacts, and responsible sourcing, organisations need to strengthen their due diligence frameworks and prepare for increasing compliance expectations.

To help businesses navigate these developments, we are launching a webinar series covering four key regulations shaping the future of due diligence in the EU:

• 16 July 2026 – EU Forced Labour Regulation (EUFLR) (already passed, please contact us if you would like to share the recording)
• 3 September 2026 – EU Deforestation Regulation (EUDR)
• 1 October 2026 – Corporate Sustainability Due Diligence Directive (CSDDD
• 5 November 2026 – EU Battery Regulation (EUBR)

Reach out to us for registration details.

PwC’s annual VAT event takes place on 9 September 2026 at the Hotel Bellevue Palace in Bern, offering a full-day programme including lunch and networking apéro.

• Practical VAT insights: Participants will receive concise updates on current VAT developments in Switzerland and the EU, with first-hand perspectives from the Swiss Federal Tax Administration, the EU Commission, PwC specialists and business representatives.
• Real-world case studies: The agenda includes practical examples from companies, including the SAP S/4HANA implementation at Allianz Suisse, as well as VAT/transfer pricing and customs/VAT cases.
• Focus on key risk areas: The conference will address current case law, customs and VAT, e-invoicing, reporting, transfer pricing and technology - highlighting common pitfalls and ways to mitigate risk.
• Designed for VAT and tax professionals: The event is aimed at heads of tax, VAT managers, CFOs, finance and tax managers, accounting, controlling, compliance and legal professionals dealing with VAT and indirect tax matters.
• Networking opportunity: Attendees can exchange views directly with PwC experts, speakers from public authorities and industry peers during breaks, lunch and the evening apéro.
• Language: The conference will mainly be held in German, with several sessions delivered in English. An AI translation tool will be available to all participants; attendees should bring their own smartphone and headphones.

Find out more and register here.

In its judgment of 25 March 2026 (A-3704/2024) the Federal Administrative Court denied input VAT recovery in respect of eight invoices that did not comply with the formal requirements set out in Article 26(2) of the VAT Act. In particular, the invoices did neither indicate the rate nor the amount of the tax and the Court confirmed that the mere inclusion of the reference “TTC” (Toutes Taxes Comprises / all taxes included) is not sufficient to satisfy these requirements.

• Implication for companies: This serves as a timely reminder to review invoice formalities upon receipt and to request any necessary corrections without delay.

• ZAZ account is being replaced by GP-ID: In the new customs system Passar, the Business Partner ID (GP-ID) will replace the existing ZAZ accounts for the payment of import duties/taxes in commercial goods traffic. Companies must complete a one-time registration as a business partner in the federal ePortal, using either the role "document retrieval in goods traffic" or "freight", together with the role “financial information”.
• No automatic migration: An automated transfer of ZAZ accounts to a GP-ID is not possible - registration is the responsibility of each company itself. Only one GP-ID may be registered per UID number or BUR-ID, though a free-text field on the customs declaration can be used for internal differentiation. BAZG is also examining whether existing direct-debit arrangements (eBill/Direct Debit) can be carried over to the GP-ID without requiring a new application.
• Parallel operation of e-dec and Passar: The switch from the ZAZ account to the GP-ID is tied to each company's individual transition from e-dec Import to Passar Import, or to the corresponding transition by its customs agent. During the transition phase, both systems run in parallel: e-dec imports continue to function as before (including use of the ZAZ account), while Passar imports are linked to the GP-ID - including for document retrieval.
• New security concept: Thanks to the new "debtor status," it will be possible to move away from generally requiring security deposits from companies domiciled in Switzerland or Liechtenstein; instead, risk-based instruments such as claim-related security deposits or immediate payment will be used. A complete blocking of a business partner, as previously occurred under the ZAZ system, is no longer envisaged (guarantees for international transit procedures remain unaffected).
• Traffic-light debtor status: The status is assigned automatically after ePortal registration and indicates whether imports can be settled on invoice. It switches to "red" when invoices are at least 30 days overdue (second reminder stage), or when a required security deposit is missing or insufficient; once payment is booked or the security deposit adjusted, the status automatically reverts to "green," which can take up to 28 hours (excluding weekends). Regardless of the status, payment can always be made directly at the customs office. 
• New ePortal service "Finanzas": A financial portal will be introduced within the ePortal, giving companies visibility over their debtor status, including any measures required if the status is “red”, as well as open and overdue invoices, security deposits and documents via Chartera. The service is expected to be available from 1 September 2026. Until then, and during the pilot phase, security deposits must be arranged directly with BAZG.

After years of regulatory ambiguity, the EU has now codified what enforcement trends have long signaled: financial transactions in pharmaceutical wholesale distribution are officially regulated. The EU pharmaceutical reform, now in its final legislative stages, includes Article 166(1)(c) of the Pharmaceutical Directive, which requires wholesale distribution authorisation holders to procure medicinal products, including by financial transactions, only from EU/EEA-authorised entities. This closes the door on arrangements where products are physically stored and distributed in the EU/EEA while the contractual or economic supplier is a non-EU/EEA entity, such as under a Swiss principal model. This codification builds on a clear trajectory of case law from Germany, the CJEU, and Sweden, all of which affirmed that controlling the financial supply chain, not just physical logistics, is what matters for compliance.

While a transitional period extends into 2028 for national transposition, companies should not mistake this for breathing room: national health authorities are already enforcing these principles today under existing GDP requirements, and non-compliance can trigger major inspection findings or supply disruptions. Redesigning an operating model to align financial and physical flows is a complex, cross-functional undertaking spanning regulatory, tax, transfer pricing, operations, and IT, that typically takes up to 12 months. The good news is that the Swiss principal model isn't obsolete; compliant solutions exist that preserve its strategic and economic benefits while meeting EU/EEA expectations, provided the redesign is approached as an integrated, cross-functional effort from the outset.

Read more here.

The OECD's discussion draft on Chapter VII, open for comment from 1 June to 22 July 2026, is a significant marker for groups with material intra-group service flows. Framed as modernisation rather than a change of principle, it aligns the services guidance with the accurate-delineation and comparability foundations in Chapters I to III: delineation must precede method selection, no automatic recourse to one-sided pricing is permitted, and the benefit test is refined—expected benefits can suffice, loss-making recipients do not negate a service, and the test operates entity-by-entity. It expands treatment of shareholder activities and signals that any recognised method, including profit split, may fit higher-value arrangements. 

Substantively, the draft raises the evidentiary bar: a labelled service fee or written contract is no longer presumptive proof that a service was rendered, and it displaces the reflexive cost-plus default in favour of functional analysis of a service’s contribution to value creation. Groups are expected to hold contemporaneous evidence of expected benefits—project materials, technical reports and coherent cost-allocation support—rather than high-level narratives, with illustrative examples covering data-driven services that may lack reliable comparables and non-low-value services justifying mark-ups below 5%. 

Read as an enforcement signal, the proposals point toward a more structured audit examination that tests independently whether a service exists, whether it confers an identifiable benefit, and how it should be priced—particularly where authorities challenge both substance and quantum in low-cost jurisdictions comparing intra-group fees against local providers. For controversy practitioners, it foreshadows a more fact-sensitive, evidence-led reorientation of audit focus and documentation standards.

• More insights: OECD consultation on intra-group services
• Event: Public consultation on taxation: Revisions to Chapter VII of the OECD Transfer Pricing Guidelines

In our "Nachgefragt" series, we engage in conversations with subject-matter experts to examine the latest developments in the field of transfer pricing. The diverse perspectives offered afford a comprehensive view of the challenges at hand and provide valuable food for thought for transfer pricing practitioners. 

In this blog, we speak with Maurizio Borriello, Head of the Transfer Pricing Section at the State Secretariat for International Finance (SIF). The SIF serves as Switzerland's Competent Authority in tax matters vis-à-vis foreign states and is accordingly responsible for negotiating Advance Pricing Agreements (APAs) and Mutual Agreement Procedures (MAPs) with partner jurisdictions. Particularly against the backdrop of growing global tax uncertainties, Switzerland is positioning itself as a bastion of stability. 

In our conversation, Maurizio Borriello explains how the SIF prevents international double taxation through the highest standards of efficiency in dispute resolution, and why the Swiss approach is becoming a decisive locational advantage precisely in these complex times.

Transfer Pricing Perspectives DACH – Ausgabe 70

The cost plus method is one of the standard transactional methods used to determine transfer pricing and is applied in particular to intra-group services and routine functions such as contract manufacturing or toll manufacturing. Under this method, the costs incurred by the service provider are identified and then increased by an arm’s length profit mark-up.

Although the underlying principle appears straightforward, a recurring practical issue is which costs should be included in the cost base. This question can also give rise to disputes, in part in the cross-border context between Switzerland and Germany.

Transfer Pricing Perspectives DACH – Ausgabe 70