When the tax authorities value the company at 6 times its net assets

Taxpayers hold a stake in a company. They complete their tax return and declare the substance value.

The tax authorities, in their taxation, substitute another value which is 6 times higher than the underlying value. The tax authorities took the return into account to determine the company's fiscal value. And the return was comfortable. The tax authorities applied the instructions of the finance directorate, instructions which are published and which reproduce circular CSI No 28 on the estimation of unlisted securities.

Federal judges recall that the valuation principles described in Circular CSI No. 28 are accepted valuation methods, but that other recognised valuation methods are also possible when adapted to the concrete circumstances.

They note that the tax authorities had taken into account certain specific elements of the case and that the method was correct.

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

Federal Supreme Court, judgment 9C_380/2025, of 25 February 2026