Never give up!

Each year, the taxpayer fulfils their tax obligations, only to be automatically taxed twice. The tax authorities discover that the taxpayer has undeclared bank assets and initiate proceedings for tax recall and evasion for the past 10 years. The taxpayer contests the existence of new facts that would allow for the reopening of past tax periods. They state that they sent an email to the tax authorities concerning the bank assets considered by the tax authorities to have been omitted. They also request that their travel expenses incurred for managing their foreign properties be considered as property maintenance costs.

The taxman believes there are indeed new facts and proceeds with a tax adjustment.

Federal judges note that the taxpayer did indeed send an email concerning the tax year prior to the one in question, but relating to matters other than the omitted bank holdings. For the tax year in question, he allowed himself to be assessed by default. The taxpayer's argument fails.

Regarding travel expenses for managing foreign properties, federal judges point out that while deductions can be claimed in an tax reassessment procedure, they must relate to the omitted items to be admissible (cons. 3.3.1). This is not the case here. Furthermore, these travel expenses were already known at the time of the assessment. Finally, these travel expenses are not tax-deductible property maintenance costs.

The judgment is in German. It is a Zurich case.

Federal Tribunal, ruling 9C_228/2025, of 25 November 2025