Swiss tax authorities are participating in the widespread effort of countries and support Swiss taxpayers.

As part of the countries masterplan and stimulus package to counter the economic impact of the Covid-19 pandemic, the Swiss Federal Government provides for a number of tools to keep liquidity going:

• Waiver of late payment interest with regard to Swiss VAT payments due between 20 March 2020 and 31 December 2020;
• Waiver of late payment interest with regard to direct federal taxes due between 1 March 2020 and 31 December 2020;
• Governmental agencies are requested to check credits due to companies and individuals and make repayments without meeting payment deadlines / awaiting due dates;
• Simplify the access to request a deferral on taxes due and application for payment schemes;

Waiver of late payment interest

Direct Taxes

The payment of direct federal taxes in relation to 2019 is due on 31 March 2020. Payments past the due date are generally subject to a late payment interest of 3% p.a. In order to ease the burden of taxpayers the Swiss Federal Government introduced with immediate effect as of 20 March 2020 a waiver of late payment interest until 31 December 2020. The waiver does not apply with regard to penalties or administrative costs due.

The Swiss Federal Tax Administration further clarified the position of the Swiss Federal Council in an explanatory statement issued on 24 March 2020. Accordingly, all provisional and final invoices with regard to direct federal taxes – covering all tax periods subject to assessment – with a payment due date between 1 March 2020 and 31 December 2020 are covered by the waiver of late payment interest. This means that not only direct federal tax 2019 is affected by this measure but also any other tax years for which a direct federal tax invoice would become due between 1 March 2020 and 31 December 2020.

In addition to the Swiss Federal Tax Administration, a majority of Swiss cantons is introducing similar support measures and extending payment deadlines or waiving late payment interests for cantonal and communal taxes as well.

Other Taxes

The waiver of late payment interest by the Swiss Federal Government does not apply to direct taxes only. To ease the cash-shortage of entrepreneurs, the measures further allow deferring payments in relation to a number of other taxes without late-payment interest or penalties. So far, the following taxes are covered:

• Swiss VAT (due between 20 March 2020 and 31 December 2020);
• Customs duties (due between 20 March 2020 and 31 December 2020);
•  Gasoline taxes (due between 20 March 2020 and 31 December 2020);
• LSVA/Schwerverkehrsabgabe (due between 20 March 2020 and 31 December 2020);
• Beer / alcohol and tobacco taxes (due between 20 March 2020 and 31 December 2020);

Checking tax/other credits with the governments

The Swiss Federal Government and a majority of Swiss cantons have advised all governmental agencies and authorities to “check” and process any credits in favour of a taxpayer and arrange for immediate repayments without considering the usual repayment terms and deadlines.

“Defer” payments due & application to payment schemes

Both, tax laws at federal level and cantonal level, allow taxpayers to request a deferral of payments due without any late interest on open tax payments (e.g. following a final assessment) becoming due in case of hardship. To ease the pressure on taxpayers, the tax laws allow for payment schemes to be agreed between taxpayers and the respective authority.

In the wake of Covid-19, the Swiss Federal Government urges authorities to ease the access to the respective deferral of payments and respective payment schemes.

If you would like to discuss more on this topic, please do reach out our key contacts below.

Key Contacts

René Zulauf - Partner, International Tax

René has 20 years of experience in the field of international tax structuring, financial services tax and Mergers & Acquisitions. He specializes in cross-border tax planning and has assisted numerous multinationals in particular in the establishment of Swiss finance and IP structures, as well as in the structuring of Swiss trading and principal/headquarter operations.

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Daniel Stutzmann - Partner, International Tax

Daniel is a Tax Partner with more than 10 years of experience as an international corporate tax specialist. This includes a one year assignment in the US to lead the Swiss ICE Desk. Daniel has extensive experience in the area of cross-border structuring (like establishing tax efficient IP- and financing structures) as well as business reorganizations including large supply chain transformation projects. This also includes advising several multinationals in moving their worldwide/regional headquarters or central functions to Switzerland, while often establishing tax privileged Swiss principal companies. In his capacity as Swiss tax expert he has worked on a significant number of value chain alignment (“VCA”) projects, cross border restructuring and headquarter relocations.

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Ferdinando Mercuri - Partner, International Tax

Ferdinando has over 15 years of professional experience within the tax consulting to companies, as well in the industrial field as in the services companies. In addition to his function of Partner at Deloitte, he also teaches tax law in Western Switzerland and he is responsible of the International Tax Module for the French part of the Swiss Tax Academy

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Jacques Kistler - Partner, International Tax

Jacques is the Lead Partner of our Corporate Tax service line in the French Speaking part of Switzerland, covering international tax and M&A. He has been a full time International Corporate Tax specialist for over 23 years.

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Manuel  Angehrn – Senior Manager, International Tax

Manuel is a Senior Manager in the International Tax practice of Deloitte Switzerland. He has over 6 years of experience providing Swiss and international tax advisory and compliance support to multinational enterprises across a spectrum of industries including the life science, consumer business, financial services and manufacturing. He further supports private clients with their tax matters.

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