VAT for platforms: who is really making the supply?

The order looks routine: a Swiss buyer selects a product, pays through a marketplace and waits for delivery. Since 1 January 2025, however, the VAT treatment may tell a different story from the interface. In some cases, the platform operator is deemed to buy the goods from the seller and then supply them to the customer. One commercial sale becomes two successive supplies for VAT purposes. This change does not apply to every platform or every transaction. It depends on the goods, place of supply, order journey, contract and revenue connected with the sale. This article therefore follows a transaction from end to end: classifying the platform’s role, collecting evidence, considering possible VAT liability and segmenting businesses for outreach. It also shows how a fiduciary can turn a broad question into a paid diagnostic and build multichannel acquisition without claiming that regulatory change automatically creates clients. General analysis updated on 6 August 2026. It does not replace a tax assessment of the specific facts or a ruling by the authority.

Article 20a changes the attribution of certain sales of goods: when a platform brings seller and buyer together so that they conclude the contract through its interface, the operator may be deemed to make the supply to the buyer. VAT then treats the transaction as two successive supplies even if a third party physically ships the product.

The first deemed supply runs from the seller to the platform operator. The second runs from the operator to the buyer. This “deemed-supplier” rule does not necessarily change the logistics, but it shifts responsibility for declaring and paying VAT on the supply attributed to the platform when the operator is liable to VAT and the place of supply is in Switzerland.

The Federal Tax Administration explains in VAT Info 27 on digital platforms that each transaction must be considered separately. The name given to the model—marketplace, intermediary or software—is not decisive. The file must show what the interface actually enables the parties to conclude and who appears in the relationship with the buyer.

How does one sale become a two-stage VAT flow?

How to read the diagram. The product may travel directly from seller to buyer while VAT reconstructs two supplies. The order, invoice and VAT return must therefore be read alongside the contract and physical flow.

Text alternative. For VAT purposes, the seller supplies the goods to the platform and the platform supplies them to the buyer. Shipment may remain direct. If the platform is liable to VAT and the place of supply is in Switzerland, it declares the VAT due on the supply attributed to it.

Diagram source. Federal Tax Administration, VAT Info 27 — Digital platforms, practice applicable since 1 January 2025; Fedlex, VAT Act, Articles 3, 20a and 23.

A platform is not deemed to be the supplier when an exclusion in Article 20a applies: it does not participate in ordering, earns no revenue directly linked to the transaction, merely processes payment, hosts advertisements, provides advertising or redirects the buyer. The exclusion must nevertheless be tested against the actual transaction.

These exclusions prevent a directory from being treated like a transactional marketplace. A site that displays offers and redirects users to the seller’s shop does not play the same role as an interface on which the buyer selects goods, accepts terms and concludes the sale. A payment provider does not become a supplier merely because it collects the money.

Classification cannot, however, be reduced to ticking a feature. A platform may combine listings, ranking, payment, customer service and success-based remuneration. Its role in the order and the precise nature of its income must then be examined. The useful question is not “Which features does the site have?” but “Which features operate in this sale, and with what contractual effect?”

This table prepares a discussion; it does not deliver a ruling. The same operator may have transactions within scope and others outside it. The sample must therefore cover the journeys actually used, not only the most common or easiest scenario to present.

Goods and services are treated differently because the deemed-supplier rule introduced in 2025 covers sales of goods concluded through a platform. Transport, accommodation and other service platforms may still have a duty to provide information without becoming suppliers under Article 20a for that reason alone.

This distinction still matters in 2026. In December 2025, the Federal Council opened a consultation on extending the regime to certain electronic services. A consultation concerns a proposal; it does not make the extension effective law. Apps, games, films and music must therefore be distinguished from the rules already applying to sales of goods.

For a fiduciary, the first segmentation is between delivered goods, supplied services and hybrid models. A subscription may, for example, provide access to a service while including a physical item. A bundle requires the firm to identify what is sold, by whom and in what proportion before selecting the relevant VAT analysis.

The commercial benefit of this precision is immediate: it avoids a campaign aimed at “all platforms”. Messages can start with the mechanism actually encountered—goods sales, imported low-value consignments, hybrid models or the duty to provide information—and lead to different diagnostics. Specialisation comes from asking a better question, not adding jargon.

The CHF 100,000 threshold appears in the transitional rule for imported goods on which import tax is negligible: liability from 1 January 2025 required at least CHF 100,000 in relevant turnover during the previous twelve months and an expectation that such supplies would continue during the following twelve months.

The threshold is therefore neither a universal marketplace turnover figure nor a measure of commercial potential. It remains tied to the category of goods, their importation into Switzerland and the period concerned. A foreign platform with no registered office, permanent establishment, domicile or supply located in Switzerland may still lack a Swiss connecting factor; a platform sending low-value consignments or making other supplies in Switzerland requires closer analysis.

When introducing the revision, the Federal Council noted that the previous mail-order regime had limited reach because many small sellers remained below the threshold. Attribution to the platform is intended to aggregate sales made through it. That legislative purpose never removes the need to test the operator’s own conditions for VAT liability.

The diagnostic should collect the relevant turnover for the twelve-month period, a defensible forecast of continuity and several representative orders. It should also identify the place of supply, any declaration of subordination and the role of the customs-clearance provider. A standalone amount in a spreadsheet cannot answer these questions.

The first year shows that 57 platforms were registered for VAT under Article 20a at the end of December 2025: 31 were established in Switzerland and 26 abroad. This FTA figure confirms that the regime is in use, but measures neither every affected platform nor the prospects available to a fiduciary.

How to read the chart. Registrations were divided almost evenly between Swiss and foreign operators. This supports multilingual assistance and attention to cross-border flows, but does not justify extrapolating a total market from 57 cases.

Text alternative. The FTA counted 31 platforms established in Switzerland and 26 established abroad, a total of 57 registrations at the end of 2025. Some businesses already registered for VAT had not yet reported their platform status.

Chart source. Federal Tax Administration, 2025 Activity Report, published in April 2026.

The report also states that the FTA completed publication of its practice on the revision during the second half of 2025 and handled numerous enquiries. This supports current monitoring: it indicates a need for interpretation and implementation, but provides no average mandate value, conversion rate or campaign-attributed revenue.

A fiduciary classifies a transaction by connecting six forms of evidence: the goods sold, order journey, contract, platform remuneration, invoice and product journey. It adds the amounts and territories relevant to VAT liability. Missing evidence becomes an assigned question, never an assumption promoted to a fact.

Product teams describe the interface and its variants. Legal teams provide the terms accepted by buyer and seller. Finance traces receipts, commission, refunds and issued documents. Operations explains shipment and customs clearance. Management confirms the countries, channels and models it intends to retain.

This mapping turns a vague question—“Are we affected?”—into a bounded engagement. The first deliverable may review several representative flows, with a role matrix, missing information and decisions required. Implementation follows where necessary: registration, invoicing, accounting configuration, documentation and customs coordination, depending on the case.

A fiduciary can create continuity without inventing an artificial subscription. A new country, changed journey, added category of goods or revised remuneration model opens a genuine new decision. The fiduciary market must nevertheless distinguish event-triggered continuity from generic monitoring without a defined object.

A VAT question becomes a paid engagement when an identifiable buyer commissions analysis of a real flow before an operational decision. It may recur if the platform adds sellers, countries, product categories or journeys that change the classification. The reform’s entry into force alone cannot establish a lasting mandate.

The lowest-friction first purchase is the diagnostic: a short scope, defined evidence, a report and a list of decisions. The second stage is implementation, if required. The third is an accounting or tax mandate sustained by real events. Each stage needs its own price, owner, timeframe and evidence of delivery, agreed with the partner.

This progression also protects acquisition. A campaign does not ask a prospect to sign an annual mandate immediately. It offers to verify a situation precise enough to justify a first payment. The fiduciary can then show the difference between a one-off review and the ongoing responsibility it can genuinely assume.

An acquisition strategy should distinguish Swiss operators, foreign platforms selling into Switzerland, sellers exposed to a change in treatment and customs-clearance providers. Within each group, the strongest signal is transactional: goods sold through the interface, low-value consignments, a new country or a changed contractual journey.

A list based only on an industry code would combine software providers, comparison sites, online shops and marketplaces. Research should instead cross-reference the revenue model, product type, terms of sale, territories served and indicators of recent change: a Swiss launch, admission of third-party sellers, finance recruitment, revised terms or added logistics services.

This segmentation broadens the field without promising volume. The number of accounts matching each signal, decision language, diagnostic value and delivery capacity are established during the vertical’s economic eligibility assessment.

Multichannel acquisition combines search, content, professional networks, email, telephone, voice messages, partners and events by giving each channel a different role. Content explains the mechanism; outreach qualifies a transaction; introducers provide context; retargeting supports a decision already under way. No channel is declared a winner before measurement.

Organic and paid search answer explicit queries around Article 20a, low-value consignments and registration. Short social content exposes a classification error or missing document. Outbound prospecting then targets platforms whose journey suggests sales of goods into Switzerland, with a message tied to the observed signal rather than a generic reminder of the reform.

Calls and voice messages identify the owner of the issue. Emails put one precise question in writing. Partners—law firms, payment integrators, logistics providers and customs specialists—may see the point at which a flow changes. Workshops can bring several functions together around an anonymised transaction.

The system must measure the full path: account identified, reply, flow suitable for assessment, diagnostic proposed, first purchase signed and payment received. A click or meeting is not enough. Results from comparable campaigns, where available, remain confidential; no modelled figure appears here as observed performance.

Useful pivots concern targeting, angle, offer and capacity. If replies come from out-of-scope platforms, targeting tightens. If the topic attracts only requests for free advice, the offer makes the diagnostic more concrete. If the fiduciary reaches capacity, channels slow before response times damage trust.

Scaling remains conditional on four forms of evidence: a pool of new accounts, a diagnostic clients genuinely pay for, sufficient attributable gross margin and a team able to onboard clients. These data are not yet documented for this vertical, so its economic gate remains partner_research.

The sources defining this analysis are the VAT Act published on Fedlex, FTA practice on platforms, the Federal Council’s commencement decision and the FTA’s 2025 Activity Report. They establish the mechanism and figures cited; they prove neither commercial demand nor acquisition results.

Documents used: Fedlex, Federal Act on Value Added Tax, version consulted on 6 August 2026; Federal Tax Administration, VAT registration of platform operators and VAT Info 27 — Digital platforms; Federal Council, decision of 21 August 2024; Federal Tax Administration, 2025 Activity Report; Federal Council, consultation opened on 5 December 2025 concerning electronic services.

For a comparison with another engagement trigger, the article on company law reform examines governance rather than transactions. Related articles shown below this page continue to be generated dynamically from the English-locale registry.

A similar strategy begins with a complimentary eligibility test: getfishnet examines your acquisition challenges, the types of platform you can serve, the first sellable diagnostic, capacity and expected economics. If there is a fit, we build a tailored strategy; if not, the verdict should prevent an unsuitable launch.

The test promises no VAT registration, client or revenue. It asks whether your acquisition challenge can be connected to genuine demand, a deliverable offer and a measurable system.