Zurich, June 2026
The Federal Council intends to provide Swiss companies with administrative relief in the tax area and, on 19 June 2026, opened two consultations on simplifications concerning value added tax (VAT), withholding tax and stamp duties.
The draft proposals form part of a broader package of measures aimed at reducing the regulatory burden on the Swiss economy and strengthening Switzerland’s competitiveness as a business location.
From a corporate perspective, four measures are particularly relevant:
- the expansion of annual VAT reporting;
- relief from the obligation to submit annual financial statements for withholding tax and stamp duty purposes;
- the expansion of the withholding tax notification procedure to further intra-group relationships; and
- the simplification of the exemption/relief from issuance stamp duty in financial restructurings.
The main amendments at a glance
VAT: annual reporting for all companies
Since 1 January 2025, companies with annual turnover of up to CHF 5,005,000 have been able, upon application, to submit VAT returns annually rather than quarterly. This turnover threshold shall now be abolished.
As a result, all taxable companies could in future apply for annual VAT reporting, irrespective of turnover. According to the current draft, annual reporting would continue to require an application, the payment of instalments and the timely submission of VAT returns.
Withholding tax: expansion of the notification procedure within groups
The withholding tax notification procedure shall be expanded beyond direct parent/subsidiary relationships to payments and pecuniary benefits in other intra-group relationships.
In particular, companies whose annual financial statements are fully or partially consolidated in consolidated financial statements prepared in accordance with recognised accounting standards should be able to benefit from the expanded notification procedure.
In the case of cross-border intra-group payments or benefits covered by an applicable treaty or agreement, such as a double taxation agreement or the AIA-EU, it should be possible, upon application, to discharge the tax liability by notification. Only the final or residual tax burden would then have to be remitted to the SFTA.
Withholding tax and issuance stamp duty: fewer automatic submissions
To date, companies whose total assets exceed CHF 5 million have been required to submit their annual financial statements to the SFTA for withholding tax and issuance stamp duty purposes.
For withholding tax purposes, domestic companies should in future only be required to submit their annual financial statements if there is a taxable payment/transaction, in particular a dividend distribution or a relevant non-arm’s length transaction. The SFTA would, however, retain the right to request documents in individual cases.
For issuance stamp duty purposes, companies would only have to provide their annual financial statements upon request by the SFTA.
Issuance stamp duty: simpler relief for financial restructurings
In financial restructurings, the exemption from issuance stamp duty shall be expanded by abolishing the existing CHF 10 million limitation, which currently applies prior to any further-reaching request for waiver.
As a result, open or hidden financial restructurings of companies in need of financial restructuring should no longer trigger issuance stamp duty, irrespective of the amount contributed by equity holders, provided that the contributions are used to eliminate existing losses. Cases of stamp duty avoidance remain reserved.
Accordingly, the existing request for waiver should cease to apply, with draft Art. 12 of the Federal Stamp Duties Act being repealed.
Further timetable
The proposed amendments are not yet in force. The amendments to the VAT Act and the Federal Stamp Duties Act are subject to the facultative referendum, and the Federal Council will determine their entry into force.
The draft ordinance amendments also do not yet provide for a specific entry-into-force date. According to the explanatory report, certain amendments to the Stamp Duties Ordinance and the Withholding Tax Ordinance could be brought into force earlier than the statutory amendments.
According to the report, the ordinance amendments expanding the notification procedure may be brought into force as soon as the necessary IT adjustments have been made.
Initial assessment
The package of measures is particularly relevant for companies with regular compliance obligations vis-à-vis the SFTA. The proposed amendments would reduce periodic compliance obligations, simplify certain intra-group and financial restructuring situations and may result in noticeable administrative relief for affected companies.
In this context, it should also be noted that, for administrative relief purposes, the SFTA has already abolished the obligation for securities dealers to submit nil-declarations for securities transfer tax purposes by way of practice notice dated 22 June 2026. Accordingly, securities dealers are no longer required to submit a nil declaration if they have no taxable transactions subject to securities transfer tax in the relevant settlement period.
Groups with intra-group pecuniary benefits should review whether the planned expansion of the withholding tax notification procedure could provide liquidity advantages going forward.
Companies with high turnover should assess whether annual VAT reporting would be operationally appropriate if the turnover threshold is abolished.
However, the measures are currently still consultation proposals. The definitive statutory and ordinance wording should therefore be awaited before any operational implementation.
We will continue to monitor developments and report on the definitive implementation.