25.04.2025

«Troubles, they always come in flocks (continued – and certainly not finished)

And that's 6!

👉 After yesterday's 5 rulings, the Federal Supreme Court continues to be in good form with a sixth ruling on the issue of the place of effective management.

Headlining, Zurich and Zug, with Zurich in its favourite role of hungry ogre.

The taxpayer is active in sports consultancy (player agent?), primarily football. Its registered office is in Zug, where it sublets a workspace. Its sole director lives in Zurich. He is most often travelling in major foreign footballing capitals or in Switzerland outside of Zurich and Zug (Bern, Lausanne, Basel, Geneva).

Federal judges rule in favour of the taxpayer and Zug. Only Zug is competent to tax the taxpayer without limitation.

The judgment is in German.

TF, judgment 9C_488/2025, of 25 April 2025