Author: Federal Tax Administration (SFTA)
Source: https://www.estv.admin.ch/estv/de/home/die-estv/estv-mitteilungen.html
Publication Date: December 2025 (most recent communication)
Reading Time: approx. 6 minutes

Executive Summary

The Federal Tax Administration communicates several significant practice changes and clarifications in the areas of stamp duty, supplementary tax, income tax and withholding tax. The most important developments are: (1) the discontinuation of Refinitiv SA as a recognized data provider as of 2026, (2) new OECD-compliant rules on supplementary tax effective 2024, and (3) more flexible calculations for life annuity insurance. These changes particularly affect multinational enterprises, fund managers and securities trading firms.

Critical Key Questions

  1. Freedom & Responsibility: Who will bear sole responsibility for the correct classification of taxable securities in the future when Refinitiv ceases operations – and how transparently does the SFTA communicate transition solutions?

  2. Transparency: Will smaller securities dealers be disadvantaged who have relied on Refinitiv data, while only SIX remains?

  3. Innovation & Legal Certainty: To what extent does the SFTA support companies in the technical migration to new data providers or classification systems?

  4. International Harmonization: How consistent are the new OECD-based supplementary tax rules with international standards, and do arbitrage risks arise?

  5. Need for Action: What concrete support do affected companies receive before the year-end deadline?

Scenario Analysis: Future Perspectives

| Time Horizon | Expected Development | |--|--| | Short-term (through 2026) | Refinitiv migration to SIX; increased compliance burden for securities dealers; potential transition issues with data quality | | Medium-term (2026–2029) | Stabilization on SIX as monopoly data provider; focus on OECD-compliant supplementary tax implementation; convergence of Swiss practice with international standards | | Long-term (2030+) | Higher compliance costs for SME securities dealers; increased digitalization of tax processes; possible consolidation in securities trading |

Main Summary

Core Topic & Context

The SFTA regularly issues practice communications to provide clarity to taxpayers, administrations and authorities. The present communication block addresses four priority tax domains: stamp duty (securities trading), supplementary tax (international corporations), income tax (retirement provisions) and withholding tax (capital contributions). These communications reflect global tax law developments (OECD BEPS, GloBE rules) as well as national legislative reforms.

Key Facts & Figures

  • Refinitiv SA Discontinuation: As of January 1, 2026, Refinitiv ceases to function as a recognized data provider for stamp duty classifications.
  • SIX Financial Information AG: Remains as the only SFTA-recognized data provider as of 2026.
  • Bloomberg L.P.: Has not been recognized since August 1, 2023.
  • Supplementary Tax Minimum Rate: Application of OECD rules on hybrid arbitrage structures as of December 18, 2023 (instead of previously December 15, 2022).
  • Life Annuity Yield Component: Flexible calculation as of January 1, 2025; auxiliary rate for 2025: approx. 7% (instead of previous flat rate of 40%).
  • Conversion Discount: Maximum permitted discount remains at 33⅓%, however based on dynamic market value rather than statistical average.
  • ⚠️ Uncertain Statement: Exact transition period for securities dealers in Refinitiv migration is not precisely defined.

Stakeholders & Affected Parties

ActorImpact
Multinational CorporationsBenefit from OECD-compliant supplementary tax clarity; must however recalculate residual taxes
Domestic Securities DealersLose choice between two data providers; migration to SIX necessary
Fund ManagersNew liquidation reporting processes; higher administrative burden
Retirement Provision ProvidersFlexibility in life annuity calculations; but also increased individualization required
SMEs with Convertible BondsBenefit from 33⅓% rule, but require better documentation
Tax Authorities (Cantons)Greater need for coordination with SFTA; increased training requirements

Opportunities & Risks

OpportunitiesRisks
OECD harmonization reduces double taxation of multinational corporationsRefinitiv discontinuation creates bottlenecks and classification uncertainties for mid-market companies
Increased transparency in supplementary tax through GloBE standardsSIX monopoly could lead to higher fees and vendor lock-in
Flexible life annuity calculation enables better tax fairnessAdministrative overhead for securities dealers increases significantly
Clarity on permanent establishment status defuses international border issues⚠️ Transition chaos during data provider changeover possible
Joint and several liability rules promote compliance culture in corporate groupsSME burden through individual rulings and documentation

Action Relevance

For Decision-Makers & CFOs:

  1. Immediate Action (Q1 2026):

    • Take inventory of all systems relying on Refinitiv data
    • Plan and test SIX integration promptly
    • Consult with SFTA regarding transition questions (tax rulings)

  2. Medium-term (2025–2026):

    • Implement OECD supplementary tax reporting; particularly review residual tax allocation
    • Examine structures with permanent establishments (especially holding companies) to determine if new procedural obligations apply
    • Systematize capital contribution registration (KER); use SFTA checklist

  3. Strategic (from 2026 onwards):

    • Consider advocacy efforts: SME associations should address cost/benefit of SIX monopoly
    • Evaluate alternative classification solutions (in-house expertise vs. external services)
    • Recalibrate pension funds & retirement products in light of new life annuity rates

Quality Assurance & Fact-Checking

  • [x] Central statements on data providers and key dates verified (primary source: SFTA website)
  • [x] OECD standards cross-referenced with consolidated commentary
  • [x] Federal laws (DBG, VStG, StG, OR, KAG) referenced
  • [x] Uncertainties flagged (e.g. specific transition mechanisms for Refinitiv)
  • [x] No identified political bias or conflicts of interest in SFTA communications

Supplementary Research

  1. OECD Global Forum on Transparency and Exchange of Information for Tax Purposes
    https://www.oecd.org/tax/transparency/
    – Context on GloBE Pillar Two and hybrid arrangements

  2. SIX Financial Information Product Documentation
    https://www.six-group.com/en/products-services/financial-information.html
    – Information on data quality and interfaces

  3. Swiss Tax Conference (SSK) – Coordination Office
    https://www.fh.swiss/de/politikbereiche/direkte-steuern/
    – Federal coordination and cantonal implementation assistance

Bibliography

Primary Source:
Federal Tax Administration (SFTA) – Communications 2021–2025
https://www.estv.admin.ch/estv/de/home/die-estv/estv-mitteilungen.html

Secondary Sources & Legislation:

  1. Federal Act on Direct Federal Taxation (DBG, SR 642.11)
  2. Federal Act on Withholding Tax (VStG, SR 642.21)
  3. Federal Stamp Duty Act (StG, SR 641.10)
  4. Ordinance on Minimum Taxation of Large Corporate Groups (MindStV, SR 642.161)
  5. OECD Global Base Erosion and Profit Shifting (BEPS) – Model Rules & Commentary
    https://www.oecd.org/tax/beps/

Verification Status: ✓ Facts checked on December 12, 2025

This text was created with the assistance of Claude (Anthropic).
Editorial Responsibility: clarus.news | Fact-checking: 12.12.2025