Can I correct my accounts as I see fit?

The taxpayer prepares her accounts and files her tax return. As part of a claim procedure, she files new accounts, on the grounds that salaries had been overlooked in the initial accounting.

The tax office is refusing the new accounts.

Federal judges recall the principle of the authority of the balance sheet (or principle of determinacy of accounts – consideration 4.1).

Next, they address corrections: «In terms of balance sheet corrections, a distinction is made between balance sheet rectifications and balance sheet modifications. In the case of a balance sheet rectification, an assessment that does not comply with commercial law is replaced by an assessment that does comply with it, whereas in the case of a balance sheet modification, an assessment that complies with commercial law is replaced by another assessment that also complies with it.
Balance sheet corrections can always be made – as long as there is no definitive assessment – and must be carried out ex officio, as they allow for the rectification of a balance sheet item that infringes mandatory provisions of commercial law. They are taken into account ex officio by the tax authorities in the tax balance sheet. Balance sheet rectifications can have favourable or unfavourable consequences for taxpayers. This is not the case for amendments to the balance sheet. The principle here is that the balance sheet is definitive from a certain point onwards and no subsequent amendments can be made to it. An amendment to the balance sheet is only admissible until the tax return is filed. An amendment to the balance sheet by the taxpayer during the assessment procedure is in principle only admissible if it transpires that certain entries were made on the basis of an excusable error regarding the tax consequences. As a general rule, however, amendments to the balance sheet aimed at offsetting tax authority corrections in the assessment procedure or which are carried out solely for the purpose of tax savings are excluded. Balance sheet «corrections» motivated by such reasons should also only be admitted with the greatest reservation. (cons. 4.2)

The judgment is in German. It concerns a St. Gallen case.

Federal Tribunal, judgment 9C_203/2025, of 6 March 2026