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Swiss withholding tax: Changes to the notification procedure in the group

The Federal Council has adopted two changes to the notification procedure.


The following changes will come into force on 1 January 2023:


  • Intragroup notification procedure (forms 106/108) will be possible for all legal entities from a participation rate of 10% (previously 20%)

  • Confirmation of the notification procedure in international relations (forms 823/823B/823C) will be valid for five years (previously three)


The minimum participation rate of 10% applies to national as well as international situations, provided that no other minimum rate is required in the relevant international agreements.


The reduction of the minimum participation quota provides the companies concerned with a liquidation advantage in that more liquidity is available in the period between delivery and refund of the withholding tax. In addition, the extension of the validity of the authorisation for the notification procedure brings administrative simplifications for the taxpayers as well as the tax authorities, whereby an application only has to be submitted or processed every five years.


For any further questions or advice, please contact Remo Merz, Swiss certified tax expert,


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Remo Merz, 6 May 2022


Keywords: Swiss withholding tax, form 106, form 108, form 823, form 823B, form 823C