Swiss Supreme Court Rejects VAT Exemption for Captive Reinsurer Support Payments

• The Federal Supreme Court upheld VAT assessments for 2016–2019 against a captive reinsurer that had received support payments from its foreign parent company.
• It confirmed that the services were not VAT-exempt insurance agent/broker activities because they did not directly contribute to concluding specific contracts.
• The taxpayer’s new argument that the services were a mixed bundle with partly exempt components was rejected because it was raised too late and lacked proof.
• The Court also found that objections to the discretionary assessment were not sufficiently substantiated on appeal.
• Result: the taxpayer’s appeal was dismissed.

Source: search.bger.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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