---
title: "Swiss Federal Tax Administration employs around 1,100 staff in Switzerland; language mix: 73% German, 22% French"
sdDatePublished: "2026-08-21T13:08:00Z"
source: "https://www.baerkarrer.ch/de/publications/tax-controversy-in-switzerland-2026"
topics:
  - name: "taxation policy"
    identifier: "medtop:20000620"
  - name: "law"
    identifier: "medtop:20000121"
  - name: "administrative law"
    identifier: "medtop:20001197"
  - name: "international economic institution"
    identifier: "medtop:20000372"
locations:
  - "France"
  - "Italy"
  - "United States"
  - "Switzerland"
---


Swiss Federal Tax Administration employs around 1,100 staff in Switzerland; language mix: 73% German, 22% French

Tax Controversy in Switzerland 2026

Guide - 21. August 2026

Speaking Engagement - 20. August 2026

Guide - 19. August 2026

21. August 2026 | Guide Tax Controversy in Switzerland 2026 21. August 2026 | Guide Tax Controversy in Switzerland 2026 Legislation What is the relevant legislation relating to tax administration and controversies? Aside from legislation, are there other binding rules for taxpayers and the tax authority? Legislation governing tax administration (including non-judicial tax-assessment procedures) is generally included in the material tax legislation at the federal and

or cantonal level. These are, at the federal level: - the Federal Direct Tax Act (DBG) which regulates chiefly personal

corporate income taxes as well as wealth and capital taxes, as well as wage source withholding taxes; - the Federal Act on Withholding Taxes, which regulates Swiss withholding taxes; - the Federal Act on Stamp Duties, which regulates federal securities issue and transfer taxes; and - the Federal Act on Value Added Tax, which deals with value added tax (VAT). At the cantonal level, tax provisions are generally the cantonal tax code (which deals with cantonal direct taxes) as well as, in certain cases, the cantonal act on inheritance and gift taxes. In addition, there might be a number of cantonal or Municipal tax provisions that are relevant to tax administration. Further materially relevant rules relating to tax administration can further be found in federal, cantonal and communal ordinances and, in practice, the federal and cantonal judicial authorities' and federal and cantonal tax authorities' published practice (eg, federal Tax Administration's circular letters, federal Tax Conference's publications or cantonal guidelines). Legislation governing tax controversies, including non-judicial tax objection procedures, is based on the legal foundations as set out above. The legislation for judicial (appeal) proceedings is partially also rooted in the material tax acts at federal and cantonal levels. In addition, there are specific federal procedural laws federal (eg, the federal Act on Administrative Procedure, the federal Act on the federal Administrative Court and the federal Act on the federal Supreme Court), as well as the cantonal procedural laws. With regard to the international exchange of financial information, the federal Act on Automatic Exchange of Information and the federal Act on Administrative Assistance in Tax Matters contain important procedural elements. This chapter mainly focuses on income, wealth, corporate income and capital taxes governed by the DBG unless otherwise mentioned. Legislation governing tax administration (including non-judicial tax-assessment procedures) as well as material tax law is based on the Swiss Federal Constitution and cantonal legislation. Relevant authority What is the relevant tax authority and how is it organised? The administration of taxation in Switzerland is divided between the federal tax administration, the 26 cantonal tax administrations and the communal tax authorities. - The cantonal tax administrations are generally responsible for the assessment (and, depending on the canton, the collection of) cantonal taxes, some federal taxes (ie, direct taxes) as well as, depending on the canton, certain municipal taxes. - In addition to certain political functions and its coordinating functions with regard to other Nations in the context of double taxation and information exchange, the federal tax administration is responsible for the assessment of VAT (except on imports), federal withholding taxes and federal stamp duties. Furthermore, it supervises the cantonal tax authorities in their assessments of Federal direct taxes. Customs duties and import VAT are administered by the Federal Customs Administration. - Social security contributions are administered by separate, often cantonal, authorities, under supervision (for Federally regulated social securities) of the Federal authority for social security. To give an order of magnitude, the Swiss Federal Tax Administration (FTA) employs a total of around 1,100 employees, amounting to approximately 1,000 full-time equivalents, which has been slightly decreasing since 2018. 41.6 per cent of the FTA employees are women. Approximately 73 per cent of the FTA employees are German-speaking, 22 per cent French-speaking and 5 per cent Italian-speaking. ENFORCEMENT Verification of compliance with tax laws How does the tax authority verify compliance with the tax laws? Does this vary for different taxpayers or taxes? Most Swiss direct taxes (such as income and corporate income taxes) are levied in a so-called "mixed-assessment" procedure. That is, taxpayers receive tax returns with a deadline to file them. They are then responsible to file the return and to declare the taxable objects themselves based on their qualification and assessment of the relevant taxable (and tax-exempt) factors, and the tax authorities subsequently verify the information submitted in the individual's or entity's tax return form (namely, compliance with the tax laws and practice) and determine the amount of tax in the assessment decision in each case. The tax authorities' review of submitted forms is, particularly for entities, supplemented by recurring and non-recurring (namely, extraordinary) audits performed by the tax authorities or a mandated service provider on-site. On the other hand, most taxes levied by the FTA (such as the federal withholding tax) and social security contributions are levied on the basis of a self-assessment procedure. This means that the taxpayer is responsible to know when and if a tax declaration and payment is necessary. In order to verify compliance, the FTA generally audits taxpayers at irregular intervals. This means that multiple open tax years are reviewed at the premises of the taxpayer or their accountant by one or more officers of the FTA. Tax return review procedure and limitation periods What is the typical procedure for the tax authority to review a tax return and how long does the review last? What limitation periods apply? In a typical procedure for direct taxes, after its submission, the tax return is summarily reviewed for formal compliance (timeliness, signatures, completeness of annexes etc). The tax return is recorded in the electronic assessment system and, subsequently, its content is verified. If necessary, the tax authority may undertake further investigations, whereby the authorities determine on a case-by-case basis which information is required for correct and complete taxation. If the information provided by the taxpayer is deemed incomplete, the authorities may request information from the taxpayer and from third parties (eg, employers). If such further investigations do not lead to satisfactory results, the tax authorities take a discretionary assessment by deciding unilaterally on the taxable income, profits, wealth and capital. The tax authorities' assessment is brought to the taxpayer's attention by way of a formally issued tax assessment order, including the applicable taxable elements, as well as specifying the available legal remedies. The duration of a tax return's review differs depending on the authorities' internal organisation and workload. A duration of two to three years for more complex cases may not be excluded; in principle, the tax authorities are only bound by the limitation periods. The legislation on limitations periods is quite complex and depends on whether a failure to pay tax constitutes an (administrative or criminal) offense at the same time, which is generally the case. Generally speaking, the limitations period is 10 years for direct taxes and five to seven years for taxes assessed at the federal level and social security contributions (with some exceptions and specificities). The taxation of certain capital income streams (mostly dividends) for individuals and entities is, further, secured via Verrechnungssteuer, a federal withholding taxation mechanism. Further income streams paid to individuals (eg, wages for certain resident aliens, payments to foreign resident wage recipients, board fee or pension recipients) are secured through Quellensteuer, a source tax (wage withholding tax) mechanism. In certain circumstances, intra-group dividend payments (to entities) may benefit from a notice procedure (Meldeverfahren) instead of the regular tax payment. Compliance with the respective legislation and practice is typically also monitored by the competent authorities by recurring and non-recurring audits. Tax authority requests for information What types of information may the tax authority request from taxpayers? Can the tax authority interview the taxpayer or the taxpayer's employees? If so, are there any restrictions? Under the taxpayer's general duty to cooperate in the tax assessment, the taxpayer is obliged to do everything possible to allow for a complete and correct assessment. The tax authority may, in this context, request written or oral (interview) information from the taxpayer. The most important obligation to cooperate is the submission of the tax return. In addition, in certain cantons, employers are required to directly submit salary certificates to the tax authorities. The assessment authorities may, further: - call experts; - conduct visual inspections; and - review accounts and receipts on the spot by way of auditing. In this context, Swiss law provides that companies and entrepreneurs must keep their books and records available for at least 10 years for Federal income tax and up to 20 years for VAT. Generally speaking, in an administrative (non-criminal) Swiss tax procedure there is no right for the tax authority to interview a taxpayer's employees nor to generally interview witnesses. In recent years, we have observed Federal and Cantonal tax authorities start to make use of international mutual assistance in administrative and

or criminal matters to shed light on more serious tax cases (in particular: serious cases of indirect tax fraud). Taxpayer failure to provide information What actions may the tax authority take if the taxpayer does not provide the required information? If the taxpayer does not provide the required documents or information, the tax authority may infer facts to the detriment of the taxpayer and determine the taxable basis based on a discretionary judgment called "Einschätzung nach pflichtgemässem Ermessen", "Taxation par appreciation", "Tassazione per apprezzamento". In addition, tax authorities may request assistance from other authorities and, in certain cases, even request documents and information from third parties. Finally, in specific cases where criminal offenses have been committed, the tax authorities may also resort to further investigative tools such as house inspections, seizure of bank records etc. This specific kind of cases is quite rare in practice (approximately 6-12 cases per year). Further, the failure to meet the obligations to deliver certificates, provide information and meet reporting obligations may be punished with administrative and

or criminal penalties. Protecting commercial information How may taxpayers protect commercial information, including business secrets or professional advice, from disclosure? Is the tax authority subject to any restrictions concerning what it can do with the information disclosed? An important restriction for tax authorities to enforce the disclosure of commercial information is set by the principle of proportionality. There is a balancing of interests between the protection of professional secrecy and the public interest in setting into effect lawful and equal taxation. Further, from the perspective of reasonableness, it is permissible in particular to refuse to provide specific information (eg, client names within the framework of the taxation of an attorney) that falls under legal confidentiali