Tax controversy services
Our services include pre-filing controversy management as well as the representation of our clients before authorities and courts.
Areas of expertise
- Preparation and negotiation of advance rulings
- Preparation of tax documentation
- Response to information requests and audit queries from tax authorities
- Support in tax audits
- Representation in proceedings before the competent authorities
- Advising businesses in implementing tax controversy management best practices
Recognitions
MLL’s tax team is best known for its tax-efficient structuring, regulatory and tax controversy expertise, transactional support and tax planning for private clients
Publications
Blickpunkt International
Steuer Revue, Oktober 2019, S. 700-710- DE
- Markus Frank Huber
- Sita Mahawattage
- Fabian Berr
- Nate Zahnd
- Michèle Sidler
Die Quellenbesteuerung von bestimmten Einkünften in der Schweiz
Jusletter, 7. Oktober 2019- DE
TRAF – Swiss Tax Reform
Hosts and Speakers at MLL Tax Event, Geneva, 7th October 2019- EN
STAF – Schweizer Steuerreform
Organisatoren und Redner am MLL Tax Event, Zürich, 1. Oktober 2019- DE
Firm News
News Portal
2026 Safe Harbour Interest Rates for Swiss Tax Purposes
On 29 and 30 January 2026, the Swiss Federal Tax Administration published its annual circulars on the safe harbour interest rates for loans in Swiss francs and foreign currencies. The new circulars reflect the reduction in key interest rates in the major currency areas, with the exception of Japan, over the last 12 months.
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2025 Safe Harbour Interest Rates for Swiss Tax Purposes
On 27 and 28 January 2025, the Swiss Federal Tax Administration published the 2025 editions of the two circulars on safe harbour interest rates. The Administration uses the 5-year SWAP rates and the yield on long-term bonds in the various currencies as a basis, which rebounded at the end of 2024 despite central bank rate cuts. For this reason, compared to 2024, the safe-harbour interest rates are falling only for CHF denominated loans, while they remain the same for EUR (2.50 %) and USD loans (4.25 %) and are rising for GBP (4.50 %) and JPY loans (1.25 %).
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2024 Safe Harbour Interest Rates for Swiss Tax Purposes
On 29 and 30 January 2024, the Swiss Federal Tax Administration published the 2024 editions of the two circulars on safe harbour interest rates. The revised rates in the circulars reflect the sharp drop in long-term interest rates in the major currency areas in the last quarter of 2023. The rate for EUR denominated loans declined to 2.50 % (previous year: 3.00 %), the rate for GBP dropped to 3.75 % (previous year: 5.25 %). The JPY rate remains unchanged at 0.50 %, while the USD rate climbs to 4.25 % (previous year 3.75 %).
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Don’t Panic if the Postman Rings
Important news from the Value Added Tax (VAT) department: The Swiss Federal Tax Administration (SFTA) changed the VAT practice regarding the qualification of native tokens with governance function. All existing rulings concerning the qualification of such tokens are currently re-assessed. The SFTA communicates this practice change by individual letters to taxpayers who have previously obtained VAT advance rulings rather than by public announcement.
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New Update on the Taxation of Crypto Projects from the SFTA – Taxation of DAOs Remains Hidden Topic
On 19 October 2023 the Swiss Federal Tax Administration («SFTA«) provided new guidance on the taxation of blockchain related projects in the updated version of the “Dossier Tax Information: Cryptocurrency”. Further details on the tax treatment of non fungible Tokens, airdrops, staking and the token issuance to employees are presented. Unfortunately, the SFTA remains mostly silent on the taxation of DAOs.
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