Swiss Supreme Court Rules on VAT for Sports Tournaments

The Swiss Federal Supreme Court published a ruling in a case concerning the VAT treatment of tournament entry fees charged and collected by the VAT-registered Association that organized the annual Grand Prix tennis tournament series, and the Federal Tax Administration (FTA). The Court's decision provides essential guidance on VAT treatment and input tax recovery for sporting events and similar activities.

Facts of the Case and the Final Ruling

In 2021, the FTA conducted a tax audit covering the years 2015 to 2019 and concluded that the Association was the actual organizer of the tournament series and that the entry fees paid by participating tennis players were attributable to it. 

Since the tournaments qualified as VAT-exempt activities, the FTA further determined that the Association was not entitled to deduct the input tax incurred on the related transactions. As a result of these findings, the FTA imposed an input tax adjustment of CHF 79,500 (around EUR 85,500), which it demanded in an October 2021 assessment notice. 

After the FTA upheld its decision on two occasions in June 2023 and July 2024 following the Association's appeal, the Association appealed to the Federal Administrative Court (FAC). However, the FAC dismissed the appeal in its August 2025 judgment, prompting the Association to file an appeal in public law matters with the Federal Supreme Court. In its appeal, the Association sought the annulment of the FAC's ruling, and either the referral of the case back to the FTA for a reassessment of the tax claim, or, alternatively, a return to the lower court.

In the analysis section of the case, the Court noted that, based on the tournament regulations, the website presentation, and the registration process, an objective third party would regard the Association as the provider of the relevant services. 

In contrast, the Association stated that it was only a technical platform or a direct representative of the individual tennis centers. From that position, the entry fee is paid to the respective centers and covers only court rental, making it comparable to online booking platforms such as Airbnb or Booking.com. Accordingly, the Association held that treating it differently constitutes unequal treatment in violation of the constitutional principle.

The Court determined that the participants primarily pay to take part in the nationwide competition, not for local court rental, meaning the decisive service for VAT purposes is the organization of the tournament series itself. Consequently, the Association is deemed the service provider of the tournament series, dismissed the appeal in full, and thus upheld the disputed input tax adjustment.

Conclusion

The Court's findings and interpretation underscore that entities presenting themselves as organizers of nationwide sporting events will be treated as service providers, regardless of their internal arrangements or payment flows with local venues. Moreover, if the participation fees relate to VAT-exempt sporting activities, no input tax deduction is available. Sport organizations and event organizers must carefully assess their external role and VAT exposure when structuring tournaments and similar activities.

Source: Swiss Federal Supreme Court