Switzerland: Tax Authorities

In a new landmark ruling 2C_506/2024 dated 4 May 2026 (intended for publication in the official collection), the Swiss Federal Supreme Court addressed for the first time the scope of attorney-client privilege where correspondence between a lawyer and a domestic tax authority is to be produced by that authority in response to a request made by a foreign state in international tax administrative assistance proceedings.

Kellerhals Carrard advised Spitäler Schaffhausen on a complex financing transaction involving a CHF 60 million subordinated credit agreement with Canton Schaffhausen and a CHF 100 million syndicated credit facility led by Zürcher Kantonalbank. The transaction enables the hospital to finance the renewal and development of its infrastructure following voter approval in a 2025 referendum.

Swiss lump-sum taxation is often described as if Switzerland offered a fixed annual tax package for wealthy foreign residents. This is misleading. In legal terms, taxation according to expenditure is a method for calculating a taxable base. It is not a flat fee, a separate tax rate or a Swiss residence permit. The real annual cost is usually driven by the highest relevant calculation input, not by the lowest published minimum.

For many years, there have been efforts to eliminate the unequal tax treatment of married and unmarried couples, commonly referred to as the “marriage penalty”. The inequality lies in the fact that, under current law, the income and assets of a married couple are aggregated for income and wealth tax purposes, respectively, whereas this is not the case for unmarried couples.

In a world characterized by increasing global mobility and transnational lifestyles, dual citizenship is gaining importance. Since January 1, 1992, it has been permitted in Switzerland without restriction.

On 8 March 2026, Swiss voters approved the Federal Act introducing individual taxation, with 54.3 % voting in favour. This marks a fundamental shift in the taxation of individuals: going forward, all persons...

Swiss voters have clearly rejected the inheritance tax initiative (official name: "initiative for a social climate policy – financed fairly through taxation" or in short "Initiative for a Future)"...

As cross-border remote work becomes standard practice, tax authorities are reconsidering how traditional rules apply to modern workplaces.

Das Steuerrecht für natürliche Personen betrifft zahlreiche Lebensbereiche: berufliche Tätigkeit, Vorsorge, Erbschaften und Schenkungen, Immobilien...