VAT Input Tax Adjustment Dispute Over Holding Company Dividend Investments Dismissed

In a VAT case for 2019–2022, the taxpayer received a dividend of over CHF 1.5 billion and invested most of it in cash and securities.
The Federal Tax Administration estimated an input tax adjustment and claimed an additional CHF 863,151.
The Federal Administrative Court held that from 2020 the taxpayer was no longer a holding company, so the 0.02% flat-rate adjustment for exempt financial income no longer applied.
Costs incurred by an affiliated management company after the dividend were treated as related to securities management and not eligible for input tax deduction.
The taxpayer failed to prove the estimate was clearly incorrect, so the appeal was dismissed.

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.