Switzerland – Call off stock

Call-off stock refers to the situation where, at the time of the transfer of goods to another EU member state, it is already known that the goods will be acquired by a particular taxable person, and this acquisition will take place only at a later point in time.

In the context of Switzerland (which is not an EU member but has numerous trade agreements with the EU), the call-off stock simplification can be applied under certain conditions. This means that when a company transfers goods to a warehouse in Switzerland for a specific Swiss customer, this can be done without the need for the supplier to register for Swiss VAT. Instead, the Swiss customer will account for the VAT once the goods are withdrawn from the warehouse.

However, specific conditions and requirements need to be met for this simplification to apply, and these might differ slightly from EU call-off stock rules.

All purchases of goods and services from outside Switzerland are subject to VAT when the goods or services are brought into Switzerland or used within the country. The VAT rates applied are the same as those for goods and services supplied within Switzerland by a taxable person. When goods are imported into Switzerland, the VAT charged is known as “import VAT.” In the case of services “imported” into Switzerland, VAT is levied as an acquisition tax, shifting the responsibility to tax the supply to the recipient, if the supplier is not registered for VAT in Switzerland and the place of supply is within Switzerland based on the general rule.

Taxation of Imports

Import VAT is applicable to goods brought into Switzerland from abroad. The responsibility for paying import VAT and, if applicable, customs duties lies with the importer of record, typically the recipient of the goods, regardless of whether the recipient is registered for Swiss VAT.

If a foreign supplier wishes to handle the customs clearance of goods in their own name for their Swiss clients, they can seek formal approval, known as an “Unterstellungserklärung,” from the Federal Tax Administration (FTA). This approval, which requires Swiss VAT registration, allows the foreign supplier to act as the importer of record instead of the recipient. The place of supply is considered to be Switzerland. Subsequently, the supply of goods to the recipient is subject to Swiss VAT according to the regular rules, and the supplier can generally deduct the import VAT paid as input VAT.

Import VAT is payable at the time of importation and is collected by the Swiss Federal Office for Customs and Border Security (FOCBS). Input VAT deduction for import VAT is available based on the general rules governing input VAT deductions.

Reliefs from Import VAT

Swiss VAT exemptions, as stated in Article 53 of the Swiss VAT Law and Article 113 of the VAT Ordinance, apply to the following imports, provided that the relevant requirements are met:

• Imports of human organs by recognized medical institutions and hospitals, and imports of blood by licensed individuals.
• Personal works of art created by painters or sculptors, imported into Switzerland by them or on their behalf.
• Goods exempt from customs duty, such as means of payment, securities, manuscripts and certificates without collector’s value, domestic postage stamps and other official stamps, inherited goods, goods for non-profit organizations, aid organizations or people in need, art and objects for museum exhibitions, studies and works by Swiss artists temporarily abroad for study purposes, goods from border traffic, animals from border waters, samples, and domestic packaging material.
• Imports of goods, such as aircraft and aircraft parts, as part of a supply of goods by airlines whose turnover from international flights exceeds their turnover from domestic traffic. These goods must be brought into Swiss territory by the airlines, and the airlines must have procured the goods prior to import as part of a supply of goods. After importation, the airlines must use the goods for their own business activities that entitle them to input VAT deductions.
• Supplies of electricity through cables, gas supplied via the natural gas distribution network, and district heating.
• Goods declared tax-free under international treaties.
• Goods imported into Switzerland for temporary use or under the inward processing regime, provided that entitlement to reimbursement is requested as part of the importation procedure.
• Goods returned to Switzerland after temporary export for job processing in another country (with the work performed on the goods subject to VAT under Article 54(1)(e) of the VAT Law), and goods exported from Swiss territory for temporary admission or outward job processing under a work and labor contract, which are subsequently returned to the consignor on Swiss territory.
• Goods for heads of state, diplomatic missions, consular offices, and international organizations.
• Coffins and urns.
• Honorary prizes and honors.
• Certain duty-free foodstuffs.
• Supplies, spare parts, and equipment for vessels.
• Gold coins and fine gold.

Last Updated: 09/08/2023

Disclaimer

The information provided by Global VAT Compliance B.V. on this webpage is intended for general informational purposes only. Global VAT Compliance B.V. is not responsible for the accuracy of the information on these pages, and cannot be held liable for claims or losses deriving from the use of this information. If you wish to receive VAT related information please contact our experts at support@gvc.tax