What online retailers need to consider
New VAT rules have been in effect in Switzerland since 1 January 2025 – and many retailers are asking themselves: Do I still have to declare and pay the tax myself? What applies to my platform sales? And what does a legally compliant setup for my shop look like?
This article explains the changes brought by platform taxation, outlining what retailers need to consider and how exporto can help them streamline their processes.
From 1 January 2025, a revised version of the Value Added Tax Act (MWSTG) will apply in Switzerland, with VAT adapting to digitalisation and internationalisation. The most significant amendment is the introduction of platform taxation,
which shifts responsibility for VAT on cross-border sales from individual traders to marketplaces. Reporting obligations and sanction mechanisms will also be more clearly regulated.
The revision has several objectives:
From 2025, the new regulation will legally require marketplaces and platforms, such as Zalando, Amazon and Galaxus, to pay VAT directly to the Federal Tax Administration (FTA). Until now, retailers have been responsible for paying this tax.
Additional requirements also apply:
Another new development is that the FTA may take significantly firmer action if platforms fail to fulfil their obligations or wrongfully fail to register as taxable companies.
This could include import bans on affected shipments, and in extreme cases, the destruction of goods, if violations occur repeatedly and no remedial action is taken. Additionally, the FTA may publish the names of companies it has fined to protect customers.
Let's now take a closer look at platform taxation. We already know that from 2025, platforms will have to declare VAT on sales to Switzerland directly to the FTA, pay it and assume tax responsibility for all transactions with Swiss end customers.
Article 20a of the VAT Act provides the definition:
Anyone who facilitates a delivery [...] by bringing sellers and buyers together on an electronic platform to conclude a contract is considered a service provider to the buyer.
This means that a platform is considered a service provider and is subject to VAT if it technically facilitates the purchase between a retailer and a customer – for example, by managing the conclusion of the contract via its website or app.
Providers who merely play a supporting role and meet one or more of the following conditions are not considered platforms:
In practice, this means the following, for example:
Traders who start selling to Switzerland exclusively via platforms for the first time in 2025 will generally no longer be required to register for VAT in Switzerland themselves. While they will no longer be required to declare and pay the tax themselves, some points remain relevant:
In short, the platform is liable for VAT, but traders must remain fully aware of their setup and ensure that it is accurately documented.
In certain cases, a trader may remain partially involved in tax processing despite selling via a platform – for example, if they are registered for VAT in Switzerland and have an approved ‘declaration of foreign status’. However, even then, the platform usually remains liable for tax on part of the transaction.
According to the FTA's logic, platform sales legally constitute a fictitious double delivery:
For delivery 1 ‘Dealer → Platform’, the following applies: As a rule, the platform is considered the importer of the delivery. In this case, the place of delivery is abroad and the delivery is not taxable in Switzerland. If, on the other hand, the trader acts as the importer by means of an approved declaration of subordination abroad, the delivery to the platform is considered tax-exempt in Switzerland. However, in this case, the trader is responsible for paying the import tax. The prerequisite is that the trader has a service overview from the platform showing that it has correctly declared the delivery to the FTA as subject to VAT. Therefore, this first delivery to Switzerland is not subject to VAT, regardless of who acts as the importer.
The following applies to delivery 2 ‘platform → end customer’: Regardless of whether the retailer or the platform imports the item, the platform remains liable for VAT on the delivery to the end customer.
For many retailers from Germany and the EU, the model of registering for VAT and submitting a declaration of subordination in Switzerland, regardless of platform sales, has proven successful for several reasons:
At exporto, we implement this exact setup for our customers – including registration, foreign declaration of subordination, customs clearance, tax returns and re-customs clearance (more on this later).
Anyone who sells directly to Swiss end customers via their own online shop rather than via platforms may become liable for VAT in Switzerland under certain conditions:
Since 2019, foreign retailers have been required to register for VAT in Switzerland if they generate at least CHF 100,000 in sales per year in Switzerland with small consignments. Small consignments are goods deliveries where the import tax does not exceed CHF 5 – in these cases, no import tax is levied at the border upon import. This will remain the case from 2025 onwards.
Tax liability arises if the turnover limit of CHF 100,000 is exceeded. Traders should therefore monitor this limit closely. Exceeding it means that traders
Failure to register or errors in the registration process can result in import delays, queries from the authorities, or even an import ban.
Import tax is also payable. If the trader acts as the importer, this can be claimed as input tax. This requires a foreign declaration of subordination. Although it is not legally binding, it is necessary in order to be recognised as the importer; otherwise, the Swiss end customer is considered the importer.
Without a foreign declaration of submission, the following problems may arise:
If the retailer applies the foreign declaration of submission, the end customer only pays the standard rate of VAT on the invoice. The retailer pays the import tax and can claim it back as input tax in their VAT return. This ensures that turnover is not taxed twice.
The new regulations are still causing uncertainty among many retailers. Errors often arise, particularly in mixed models – i.e. when selling via platforms and the retailer's own shop:
Scenario |
What will apply from 2025? |
What will remain with the retailer? |
What needs to be considered? |
1. Platform sales only (e. g. Amazon) |
The platform is considered the seller and pays the VAT. |
In principle, a separate VAT return is not necessary. The platform is liable in the event of errors. Import tax depending on the importer. |
Contractually clarify your role as an importer. Maintain separate revenue accounts for each platform. |
2. Own shop, < 100,000 CHF turnover with small shipments |
No obligation to register for VAT. Import tax is not levied on small consignments (≤ CHF 5). |
No VAT declaration. Import tax on higher consignment values. |
Permanently monitor the limit for small consignments. Keep import documentation tidy. |
3. Platform + shop (mixed model) |
Platform sales: VAT on platform, import tax depending on importer; shop sales: subject to VAT if threshold exceeded. |
Two setups required. VAT registration for the shop if necessary. Import tax in both channels if necessary. |
Separate accounting. Clarify responsibility for import tax per channel. Declaration of submission recommended. |
1. Platform sales only (e. g. Amazon) |
What will apply from 2025? The platform is considered the seller and pays the VAT. |
What will remain with the retailer? In principle, a separate VAT return is not necessary. The platform is liable in the event of errors. Import tax depending on the importer. |
What needs to be considered? Contractually clarify your role as an importer. Maintain separate revenue accounts for each platform. |
2. Own shop, < 100,000 CHF turnover with small shipments |
What will apply from 2025? No obligation to register for VAT. Import tax is not levied on small consignments (≤ CHF 5). |
What will remain with the retailer? No VAT declaration. Import tax on higher consignment values. |
What needs to be considered? Permanently monitor the limit for small consignments. Keep import documentation tidy. |
3. Platform + shop (mixed model) |
What will apply from 2025? Platform sales: VAT on platform, import tax depending on importer; shop sales: subject to VAT if threshold exceeded. |
What will remain with the retailer? Two setups required. VAT registration for the shop if necessary. Import tax in both channels if necessary. |
What needs to be considered? Separate accounting. Clarify responsibility for import tax per channel. Declaration of submission recommended. |
The new requirements are complex, involving platform taxation, import processes, accounting and tax registration. It is therefore worth relying on a partner who can automate these processes.
This is where exporto comes in:
Platform taxation reduces the administrative burden associated with VAT – but makes clean import and accounting processes all the more important. Anyone who also sells through their own shop must keep both sales channels separate for tax and accounting purposes.
What online retailers should do now:
Please note: This article is for general information purposes only, does not replace tax advice and does not claim to be complete or accurate. For individual questions, please contact your tax advisor or exporto directly.