SFTA – Swiss Federal Tax Administration

The Swiss Federal Tax Administration (SFTA — Administration fédérale des contributions, AFC) is the federal authority responsible for federal taxes — withholding tax, anticipatory tax, stamp duties, federal income tax (IFD) and VAT. In M&A and financial structuring, key SFTA interactions include: confirmation of capital contribution reserves (RAP) eligible for withholding tax-free distributions, advance rulings on transaction tax treatment, and withholding tax refund procedures for foreign shareholders. SFTA positions carry significant weight in cantonal tax practices.

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Example: before a CHF 15.0 million Swiss company sale, the seller's advisor submits a capital gain exemption ruling request to the SFTA — confirming the gain qualifies as private capital gain exempt from income tax. The SFTA ruling, obtained in 4 weeks, provides certainty on the CHF 12.0 million gain exemption before the transaction closes.

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Hectelion coordinates SFTA interactions — ruling requests, RAP confirmation and withholding tax procedures — in Swiss transaction structuring mandates.