- The Swiss Federal Administrative Court upheld a VAT assessment of over CHF 1 million against a Swiss captive reinsurer, confirming Swiss acquisition tax on support services received from its Italian parent.
- The court ruled the parent’s activities (risk analysis, policy review, insurer contact facilitation, claims and contract support) were not VAT-exempt insurance brokerage/intermediary services, but taxable administrative/operational outsourcing.
- For Swiss VAT purposes, intra-group services between related parties are taxable if they have independent economic value; the court found these services would normally be remunerated at arm’s length.
- Because the services were not invoiced from 2016–2018, the tax authority was allowed to estimate their value using a 2021 Switzerland-Italy BAPA, applying the 2019 profit allocation ratio retroactively to earlier years.
- The court held this discretionary assessment was methodologically sound and rejected the taxpayer’s appeal.
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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