Tax ruling

In Swiss practice, a tax ruling gives taxpayers legal certainty before implementing a transaction, restructuring, financing, employee plan or other arrangement. The taxpayer submits the relevant facts and the proposed tax analysis to the competent authority. If the authority agrees, it is generally bound by the ruling provided the facts are complete, accurate and later implemented as described, and the legal framework has not changed. Rulings cannot legalise abusive or incorrectly disclosed arrangements. They are especially important in corporate, international and high-value tax matters, but availability and procedure depend on the authority and tax type.