I am independent of the house in the neighbouring canton which is cheaper fiscally.
The taxpayer declares their income from self-employed gainful activity, carried out in the neighbouring canton with more favourable taxation.
While the tax office had acknowledged in previous years the exercise of the lucrative activity outside the canton, this time it attributes the income to the canton of domicile.
👉 Federal judges find that the taxpayer
▶️ registered its RI at the RC of the neighbouring canton, with its registered office in a «Business Office Centre»
works from his private home where he has converted a room into an office
Attends/ va au siège officiel de sa RI 24 fois par an (30 fois par an)
possesses a very rudimentary infrastructure at the head office
Workplace, meeting room, kitchenette, shared printer
Shared toilet facilities, parking
No locker, compartment, or personal cupboard.
no fixed workspace
Use of one's own computer and connection via Wi-Fi or mobile phone
forwarded mail
Phone calls diverted
Box mailbox the taxpayer's name on a simple sticker
No client appointments on-site during the entire tax period.
As the taxpayer does not dispute these facts established by the previous instance, the federal judges find that the self-employed activity is carried out from the taxpayer's home.
The ruling is in German. It is a Zurich case (no double taxation issue with Schwyz).
Federal Tribunal, judgment of 18 December 2025, case 9C_349/2025