Switzerland: tax

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Federal Tax Administration (FTA; ESTV)

Responsible for direct federal tax policy and supervision of the cantons, withholding tax, stamp duties, VAT and the international exchange of information including CRS and, once the partner-state decree is in force, CARF. The FTA publishes the working paper on cryptocurrencies, Circulars 36 and 37 and the annual price list that fixes year-end values for wealth tax.¹ Approach: for VAT and withholding tax, rulings are requested from the FTA directly in writing. For income and wealth tax, the cantonal administration is the counterparty and the FTA does not give rulings to individual taxpayers. For CARF, the FTA's AEOI unit is the registration and reporting counterparty for reporting crypto-asset service providers.

Cantonal tax administrations of Zug and Zürich

The assessing authorities for income, wealth and profit tax, including direct federal tax, which also act as the counterparties for rulings on trader status, lump-sum taxation, valuation of tokens, foundation tax exemption and employee token plans.² Approach: a written ruling request setting out the facts completely, the legal analysis and the conclusion sought, submitted before the transaction. Zug's administration is experienced with digital assets and answers within weeks. Zürich's is larger and slower but equally competent. Both bind themselves to the facts disclosed and no further.

Notes

1. Federal Act on the Federal Tax Administration's organisation is found in the Ordinance on the Organisation of the Federal Department of Finance (SR 172.215.1); the FTA's digital-asset publications are listed in Annex A4. ↩
2. The Zug and Zürich practices are compared throughout Part G; the ruling process is described in Part G, Chapter I. ↩

For general information only. This article does not constitute legal or tax advice, does not replace advice on an individual case and creates no lawyer-client relationship. It reflects the legal position as of October 2026.