- The Federal Administrative Tribunal issued a judgment on July 8, 2025 regarding a tax dispute between X SA and the Federal Tax Administration ESTV
- X SA is a company engaged in captive reinsurance activities that sought clarification on the tax qualification of reinsurance brokerage services received from its Italian parent company Y SpA
- X SA argued these services were tax exempt insurance services under Article 21 of the VAT Act and not subject to acquisition tax, but ESTV disagreed stating the services had only loose connection to reinsurance contracts
- ESTV conducted an audit for tax periods 2016 to 2019 and issued an assessment notice demanding additional taxes of CHF 1,019,221 plus interest, including CHF 1,018,297 for acquisition tax on intercompany services
- X SA disagreed with the assessment and requested ESTV to issue an appealable decision regarding the acquisition tax correction
Source: bvger.weblaw.ch
Note that this post was (partially) written with the help of AI. It is always useful to review the original source material, and where needed to obtain (local) advice from a specialist.
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