News Value Added Tax

Fiscal representation and other VAT aspects when serving Swiss customers from abroad

There is a variety of reasons for which a company domiciled abroad doing business on Swiss territory (including Switzerland, Liechtenstein and the German village of Büsingen) may VAT register on a mandatory or voluntary basis.

Typical registration obligations result among others from rendering electronic services to not VAT registered customers, installation supplies or land related services.

On the other hand, foreign companies opt for voluntary registration if they wish to supply customers within the Swiss customs territory with goods that have been customs cleared and taxed on import (DDP). In this case usually a subordination license is needed for the foreign domiciled entity to become VAT importer of records as well as a registration with Swiss customs to be able to use digital services and certain payment simplifications in connection with the import process.

The foreign domiciled entity that registers on a voluntary or mandatory basis will need to appoint a fiscal representative with domicile or registered office in Switzerland. The fiscal representative acts as local address for the foreign domiciled business towards the Swiss Federal Tax Administration for correspondence purposes. The address of the fiscal representative must also be used for the import of goods under a subordination license.

There are certain specialties in Swiss VAT law that may especially surprise companies domiciled in the EU, as Swiss VAT law punctually deviates from EU VAT law.

Extended definition “supply of goods”: A supply of goods not only includes the sale and rent of a physical good, but also the performance of work on a good located in Switzerland even if the good is not altered at all but only check for its function.

Force of attraction principle: Once an entity is registered for Swiss VAT purposes, supplies that prior to the registration had been subject to acquisition tax (Swiss version of reverse charge), must be invoiced with Swiss VAT by the supplier. A company domiciled abroad providing electronic supplies solely to companies based on Swiss territory should generally not become liable to Swiss VAT, if all customers are registered for Swiss VAT purposes. However, the first supply to a not VAT registered customer, e.g. a private individual or a branch of a foreign insurance company, all subsequent supplies, also those that were previously subject to acquisition tax at the level of the recipient, become subject to Swiss VAT at the level of the supplier.

Dual entity principle: A foreign domiciled head office and its Swiss branch (same for a foreign domiciled branch of a Swiss head office) are two separate VAT subjects under Swiss VAT law. Based on this, VAT needs to be considered for supplies between the two VAT subjects.

For further information or individual advice regarding the specific VAT options and obligations, please contact Matthias Höhn, Senior Manager VAT.

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Matthias Höhn, April 2026