Online platforms: VAT takes centre stage

Suspicions of VAT fraud in online commerce are no longer a topic reserved for major European investigations. A publication by Blast implicates, in the French and European context, e-commerce platforms accused of exploiting loopholes in VAT rules, while the tax authorities and the political world are slow to react. For a Swiss SME, the issue is not only moral or competitive: it directly affects invoicing, pricing, accounting, and the risk of audits.

Switzerland has precisely modified its system. Since 1 January 2025, Article 20a of the VAT Act provides that operators of digital platforms facilitating the delivery of goods are, in certain situations, treated as suppliers vis-à-vis the buyer. In other words, the platform can become the party responsible for collecting and remitting VAT. For companies selling online, this development changes the way sales are documented and cash flows are secured.

When online fraud becomes a competition issue

VAT is a consumption tax: it is charged to the final customer, collected by the company, and then remitted to the tax administration, with a deduction of input tax when conditions are met. In traditional commerce, the circuit is relatively straightforward: a seller, an invoice, a VAT return. In e-commerce, the scheme becomes more complex: third-party sellers, platforms, warehouses, buyers in multiple countries, returns of goods, and split payments.

It is in this complexity that the risk arises. If a foreign seller does not correctly charge VAT, if they disappear after selling, or if the platform is not clearly held accountable, the consumer sometimes gets an artificially low price. The Swiss competitor, on the other hand, includes VAT in their price, maintains accounts, submits returns, and finances the administrative burden related to compliance. The problem thus goes beyond tax technique: it affects margins and the ability to compete with online offers.

The Blast investigation mentions, for France and Europe, losses of public revenue and a constant game between new rules and new circumventions. For Swiss leaders, this signal must be read with caution: the accusations concern a foreign context and must be assessed according to the facts established by the competent authorities. But the economic mechanism is telling. When VAT is not applied equivalently, competition is distorted.

The Swiss response: bringing the platform into the VAT chain

The central change in Switzerland concerns the taxation of platforms. According to the Federal Tax Administration, operators of digital platforms facilitating the delivery of goods can be considered as suppliers of the service to the buyer. The dossier of the Federal Customs and Border Security Office specifies that this regime targets operators of platforms achieving at least 100,000 francs in turnover from such deliveries.

This logic is important: the administration no longer limits itself to looking at the isolated third-party seller. It moves up to the infrastructure that makes the sale possible. In practice, a platform that organises the connection, facilitates the order, or intervenes in the sales process can find itself at the centre of VAT processing. The rule thus seeks to prevent thousands of small sellers, who are difficult to control, from escaping tax while the platform captures part of the economic value.

For a Swiss SME, this does not mean that it is enough to delegate the entire VAT issue to the platform and forget about it. It is necessary to distinguish the fiscal role of the platform, the status of the seller, the type of goods, the place of delivery, and the accounting treatment of the amounts collected. A company selling through multiple channels may have direct sales, sales via marketplace, and cross-border sales: each must be documented consistently.

The general threshold for liability mentioned in the research dossier is 100,000 francs of annual global turnover. As soon as a company exceeds the applicable threshold, VAT registration and correct invoicing become management issues, not just tax issues. The Swiss rates indicated in the dossier are, since 1 January 2024, 8.1% for the standard rate, 2.6% for the reduced rate, and 3.8% for the special accommodation rate. The correct application of the rate, however, depends on the precise nature of the service or goods sold.

Selling on a marketplace: what the fiduciary must find in the figures

The first concrete issue lies in accounting. Platforms often provide sales reports, commission statements, refunds, logistical fees, and adjustments. These documents are not always aligned with the logic of a Swiss VAT return. For the fiduciary, the task is to reconstruct an audit trail: what amount was paid by the customer, what share goes to the SME, what commission is deducted, what VAT was charged and by whom.

A commercial margin may appear correct on a platform's dashboard, then shrink once fees, returns, promotions, shipping costs, and VAT processing are integrated. This is particularly sensitive for small e-merchants and independents who calculate their prices from the price displayed to the customer, without isolating the tax, commissions, and variable costs. Unanticipated VAT can then become a cash flow cost, or even directly erode the margin if prices have not been constructed correctly.

Contractual documentation must also be reviewed. Some platforms act as simple commercial intermediaries; others intervene more deeply in the transaction. VAT treatment is not deduced from a general impression, but from contractual conditions, billing flows, and operational reality. Before launching a new sales channel, it is prudent to ask: who invoices the final customer, who collects, who handles returns, who issues credit notes, and who declares VAT?

Signals that should trigger an internal control

In an SME, a few indicators deserve quick attention: rapidly growing sales via a foreign platform, payment statements difficult to reconcile with invoices, prices displayed without a clear mention of VAT, or customer returns processed outside the accounting system. None of these elements prove an irregularity. But they indicate that the VAT chain may not be sufficiently controlled.

The fiduciary can play a very concrete role: configure product accounts by sales channel, separate platform commissions, verify VAT entries, archive statements, and ensure that declarations match actual flows. In e-commerce, data quality is often as important as the tax rule itself. Clean accounting allows for more calmly responding to questions from the administration.

The risk is not only fiscal: it affects prices and cash flow

Faced with accusations of fraud in e-commerce, many leaders first think of the risk of sanctions. This is legitimate, but incomplete. VAT also influences pricing policy. A company selling online must know if its prices are displayed including VAT, how rate changes are passed on, and if ancillary fees follow the same treatment as the main good. A repeated error on a high volume can create a significant gap in cash flow.

The second effect concerns competition. If non-compliant sellers display lower prices, the Swiss SME may be tempted to reduce its margins to keep up. However, a price reduction does not always compensate for the advantage of an actor who does not bear the same obligations. The best response is not necessarily commercial; it can be organisational: better explaining the quality of service, securing deadlines, enhancing price transparency, and avoiding entering a price war against fiscally dubious offers.

Finally, the subject must be integrated into management decisions. Choosing a marketplace, opening an online store, selling abroad, or importing goods are not just marketing projects. They are also VAT, accounting, and logistical projects. Finance, sales, and management teams should talk before the launch, not after the first problematic return.

A recent reform, but still areas to clarify

The new Swiss framework moves towards making platforms accountable, but it does not resolve all practical questions. The research dossier notably highlights uncertainties around shared responsibility between the platform and individual sellers in case of non-compliance, as well as a grey area concerning digital services when the regulation primarily targets the delivery of goods. These points must be analysed on a case-by-case basis.

For an SME, the right attitude is neither panic nor inaction. It is necessary to map sales channels, identify the platforms used, check contracts, control transaction reports, and document VAT choices. When in doubt, it is better to obtain specialised advice before volumes increase. VAT compliance is not an administrative formality: it is protection against tax recalls, discussions with platforms, and cash flow surprises.

The European controversy reminds us of an obvious fact: in the digital economy, tax is as much about IT systems as it is about legal texts. Switzerland has strengthened its framework from 2025, but effectiveness will also depend on the rigour of companies, platforms, and controls. For Swiss SMEs, the subject deserves to be addressed now, before the marketplace becomes an accounting blind spot.