The Swiss Federal Council has proposed targeted measures to reduce the administrative tax burden on businesses. Two public consultations were held in June 2026 on proposed measures designed to modernise tax administration, simplify compliance processes and support the country’s continued attractiveness as a business location.
The proposals reflect the Federal Council’s view that Switzerland must continue to review and streamline regulation in light of international deregulation initiatives, trade policy uncertainty and increasing competitive pressure. The proposals focus on practical simplifications in areas that regularly create recurring compliance work for businesses: VAT reporting, issuance stamp duty, financial statement filings and withholding tax procedures.
A central VAT proposal would expand access to annual VAT reporting. Since 1 January 2025, businesses with annual turnover not exceeding CHF 5,005,000 have been able to apply to file VAT returns annually rather than quarterly. The proposal would remove that turnover threshold, allowing all VAT-registered businesses, regardless of size, to opt for annual reporting.
The Federal Council expects this change to reduce compliance work by eliminating the need to monitor the turnover threshold. Businesses would still be required to make advance payments, so the measure is not expected to have a significant effect on federal tax revenues. Approximately 25,000 additional businesses could benefit from the expanded annual reporting option.
The proposal also include changes to issuance stamp duty in corporate restructurings (a 1% federal tax charged when a Swiss corporation or cooperative creates or increases its equity capital). Under current law, a CHF 10 million tax-free allowance applies in restructuring cases, with possible waiver relief for amounts above that threshold where an obvious case of hardship exists. The application-based waiver process can create additional administrative work and advisory costs.
Under the proposal, the waiver procedure would be abolished and the restructuring exemption would be broadened by removing the CHF 10 million cap. Formal and informal restructurings would be exempt from issuance stamp duty ex officio, regardless of value, provided existing losses are eliminated. Companies would therefore no longer need to submit a separate waiver application. The Federal Council estimates the resulting annual revenue impact at less than CHF 10 million, while affected taxpayers may see reduced administrative work and lower advisory costs associated with waiver applications.
Another proposed simplification would narrow when companies must submit annual financial statements to the Federal Tax Administration (FTA). Currently, certain companies may be required to provide financial statements without a specific request, particularly where size-based criteria are met.
For withholding tax purposes, the obligation would be limited to companies that make taxable distributions, including dividends or deemed dividend distributions. The FTA would retain the ability to request supporting documentation in individual cases. The proposals also contemplate that relevant submissions be made exclusively in electronic form.
For issuance stamp duty, the existing balance sheet total threshold would also be abolished. Going forward, annual financial statements would need to be submitted only upon request by the FTA. Overall, the Federal Council expects approximately 45,000 businesses to benefit from these filing simplifications.
The proposed extension of the withholding tax notification procedure may be particularly relevant for corporate groups. This procedure allows qualifying taxpayers to report certain distributions to the FTA instead of paying withholding tax upfront and then claiming a refund. Under current rules, the procedure is generally limited to direct parent-subsidiary relationships. In other intragroup situations, withholding tax often must first be paid and then reclaimed through the refund process.
The proposal would permit the notification procedure for additional intragroup transactions where the relevant companies are fully or proportionately consolidated under recognised accounting standards. This change would allow deemed dividend distributions within more complex group structures to be reported directly, without first paying withholding tax. For affected businesses, the change could reduce administrative steps and avoid the cash-flow burden of paying withholding tax before claiming a refund.
In parallel with the legislative proposals, the FTA is pursuing administrative simplifications at the practice level. These include expanded digital services, greater use of electronic interfaces, and further development of eBalance and eInvoicing solutions. The FTA also plans to abolish the requirement to submit Form 9 / 9 FL for nil securities transfer tax returns. Together, these measures are intended to further reduce recurring compliance work for businesses.
The proposed measures do not amount to a broad tax reform, but they could have meaningful practical benefits for Swiss businesses and multinational groups with Swiss operations. If enacted, the changes would reduce recurring filing obligations, simplify VAT reporting options, streamline restructuring-related stamp duty relief and ease withholding tax cash-flow burdens in certain intragroup situations.
Businesses with Swiss operations should monitor the progress of the proposals and consider whether their existing VAT reporting cadence, restructuring plans, financial statement filing processes and intragroup withholding tax procedures may to be updated if the proposals are adopted.
Stefan Piller
BDO in Switzerland
The proposals reflect the Federal Council’s view that Switzerland must continue to review and streamline regulation in light of international deregulation initiatives, trade policy uncertainty and increasing competitive pressure. The proposals focus on practical simplifications in areas that regularly create recurring compliance work for businesses: VAT reporting, issuance stamp duty, financial statement filings and withholding tax procedures.
Annual VAT Returns for All Businesses
A central VAT proposal would expand access to annual VAT reporting. Since 1 January 2025, businesses with annual turnover not exceeding CHF 5,005,000 have been able to apply to file VAT returns annually rather than quarterly. The proposal would remove that turnover threshold, allowing all VAT-registered businesses, regardless of size, to opt for annual reporting.The Federal Council expects this change to reduce compliance work by eliminating the need to monitor the turnover threshold. Businesses would still be required to make advance payments, so the measure is not expected to have a significant effect on federal tax revenues. Approximately 25,000 additional businesses could benefit from the expanded annual reporting option.
Simplification of Issuance Stamp Duty in Corporate Restructurings
The proposal also include changes to issuance stamp duty in corporate restructurings (a 1% federal tax charged when a Swiss corporation or cooperative creates or increases its equity capital). Under current law, a CHF 10 million tax-free allowance applies in restructuring cases, with possible waiver relief for amounts above that threshold where an obvious case of hardship exists. The application-based waiver process can create additional administrative work and advisory costs.Under the proposal, the waiver procedure would be abolished and the restructuring exemption would be broadened by removing the CHF 10 million cap. Formal and informal restructurings would be exempt from issuance stamp duty ex officio, regardless of value, provided existing losses are eliminated. Companies would therefore no longer need to submit a separate waiver application. The Federal Council estimates the resulting annual revenue impact at less than CHF 10 million, while affected taxpayers may see reduced administrative work and lower advisory costs associated with waiver applications.
Limiting Filing Obligations with the FTA
Another proposed simplification would narrow when companies must submit annual financial statements to the Federal Tax Administration (FTA). Currently, certain companies may be required to provide financial statements without a specific request, particularly where size-based criteria are met.For withholding tax purposes, the obligation would be limited to companies that make taxable distributions, including dividends or deemed dividend distributions. The FTA would retain the ability to request supporting documentation in individual cases. The proposals also contemplate that relevant submissions be made exclusively in electronic form.
For issuance stamp duty, the existing balance sheet total threshold would also be abolished. Going forward, annual financial statements would need to be submitted only upon request by the FTA. Overall, the Federal Council expects approximately 45,000 businesses to benefit from these filing simplifications.
Extension of the Notification Procedure for Withholding Tax
The proposed extension of the withholding tax notification procedure may be particularly relevant for corporate groups. This procedure allows qualifying taxpayers to report certain distributions to the FTA instead of paying withholding tax upfront and then claiming a refund. Under current rules, the procedure is generally limited to direct parent-subsidiary relationships. In other intragroup situations, withholding tax often must first be paid and then reclaimed through the refund process.The proposal would permit the notification procedure for additional intragroup transactions where the relevant companies are fully or proportionately consolidated under recognised accounting standards. This change would allow deemed dividend distributions within more complex group structures to be reported directly, without first paying withholding tax. For affected businesses, the change could reduce administrative steps and avoid the cash-flow burden of paying withholding tax before claiming a refund.
Additional Measures at the Administrative Practice Level
In parallel with the legislative proposals, the FTA is pursuing administrative simplifications at the practice level. These include expanded digital services, greater use of electronic interfaces, and further development of eBalance and eInvoicing solutions. The FTA also plans to abolish the requirement to submit Form 9 / 9 FL for nil securities transfer tax returns. Together, these measures are intended to further reduce recurring compliance work for businesses.
BDO Perspective
The proposed measures do not amount to a broad tax reform, but they could have meaningful practical benefits for Swiss businesses and multinational groups with Swiss operations. If enacted, the changes would reduce recurring filing obligations, simplify VAT reporting options, streamline restructuring-related stamp duty relief and ease withholding tax cash-flow burdens in certain intragroup situations.Businesses with Swiss operations should monitor the progress of the proposals and consider whether their existing VAT reporting cadence, restructuring plans, financial statement filing processes and intragroup withholding tax procedures may to be updated if the proposals are adopted.
Stefan Piller
BDO in Switzerland