01 · Tax ruling
Cantonal tax confirmations, drafted and negotiated.
A written confirmation from the cantonal tax administration of how your specific structure or transaction will be taxed. Hourly engagement at CHF 250. Free 30-minute scoping call.
02 · Three common ruling types
Holding, employment, restructuring.
Holding-structure ruling
Confirmation of participation-exemption application (DBG art. 69-70), substance requirements, and any tax-treaty interaction. Typically 8–15 hours of drafting and negotiation. CHF 2,000–3,800.
Employment-tax ruling
Confirmation of expatriate / lump-sum-expatriate positions, share-plan tax treatment, or remote-work arrangement. 6–12 hours typical. CHF 1,500–3,000.
Restructuring ruling
Confirmation of tax-neutral restructuring under FusG: merger, demerger, conversion, intra-group transfer. 10–20 hours typical. CHF 2,500–5,000.
03 · Pricing
Hourly engagement. Typical totals shown.
| Service | Our fee | Market range |
|---|---|---|
| Tax ruling drafting and negotiation (hourly) | CHF 250 / hour | CHF 250–550 |
| Initial scoping consultation (30 min) | free | CHF 0–350 |
| Holding-structure ruling (typical) | CHF 2,000–3,800 | CHF 4,000–10,000 |
| Restructuring ruling (typical) | CHF 2,500–5,000 | CHF 5,000–15,000 |
Cantonal Steuerverwaltung does not charge a fee for ruling submissions. Federal stamp-duty rulings (with ESTV) carry a small administrative fee.
04 · Mandate scope
Drafting, submission, negotiation, final letter.
- Identification of relevant cantonal and federal tax positions
- Drafting of the ruling request with structured legal reasoning
- Submission to the cantonal tax administration (Steuerverwaltung)
- Tracking and response to clarification questions
- Negotiation where the cantonal authority disagrees with our position
- Final ruling letter with binding effect on the canton (subject to facts being as represented)
05 · Process
Scoping → drafting → submission → final ruling.
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01
Scoping
Free 30-minute call to confirm whether a ruling is the right tool versus a planning memo. Some matters are clearer addressed without a ruling.
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02
Drafting
Ruling request drafted: facts, applicable law, requested confirmation. 1–3 weeks. Reviewed with you before submission.
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03
Submission + dialogue
Filed with the cantonal Steuerverwaltung. Cantonal authorities typically respond within 6–12 weeks; complex rulings can take 4–6 months.
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04
Final ruling
Once issued, the ruling is binding on the canton (and indirectly on the federal tax administration where ESTV co-signs) for as long as the facts remain as represented.
06 · FAQ
Frequently asked questions.
What is a Swiss tax ruling?
A written confirmation from the cantonal tax administration of how a specific transaction or structure will be taxed. Issued before the transaction. Binding on the cantonal authority for as long as the facts remain accurate. Used to remove tax uncertainty before signing M&A deals, capital restructurings, or relocating senior employees.
How long does a Swiss tax ruling take?
Six to twelve weeks typical for ordinary positions. Holding rulings, expatriate rulings, and tax-neutral restructuring rulings: 12–20 weeks. Complex multi-jurisdictional rulings can run 4–6 months as the canton consults with ESTV (Federal Tax Administration). Filing earlier rather than later is the recommended approach when a deal timeline is fixed.
In which canton should I file the ruling?
The canton where the company is or will be tax-resident. For new companies the choice of canton determines both the ruling authority and the cantonal income-tax rate. Zug, Schwyz, Lucerne and Nidwalden are common low-tax cantons; Geneva and Zurich are common for international companies.
Is the ruling binding on the Federal Tax Administration?
Indirectly. Cantonal rulings on federal direct tax matters bind the canton, which collects federal direct tax on behalf of ESTV. ESTV can in theory diverge but in practice rarely does for properly drafted rulings. For purely federal matters (withholding tax, stamp duty) the ruling must be filed directly with ESTV.
When is a ruling worth the cost?
When the tax exposure of the issue exceeds 5–10× the ruling drafting cost, and the cantonal position is uncertain. Examples: a CHF 50m holding deal where the participation-exemption application is debatable; a senior-executive relocation where the canton's view of remote-work fragmentation matters; a restructuring where tax-neutral treatment hinges on substance arguments. For routine matters with clear law, a planning memo is cheaper and sufficient.
Can a foreign company file a Swiss tax ruling?
Yes — provided the matter has a Swiss tax nexus (Swiss subsidiary, Swiss permanent establishment, Swiss-source income, etc.). For a pure foreign-foreign transaction with no Swiss tax angle, a Swiss canton has no jurisdiction to rule. We confirm Swiss nexus at the scoping call.
07 · Get started
Tell us the position you want confirmed.
One-paragraph brief: what tax position, which canton, expected transaction date, applicable statute. We confirm whether a ruling is the right tool and quote within 24 hours.