Tax Treatment of Commissions for Self-Employed Individuals in Switzerland

At a glance

• Commissions are income from self-employment under DBG Art. 18 — not salary
• VAT obligation arises from CHF 100 000 annual turnover, tax rate 8.1 %
• AHV contribution: 9.75 % or 10 % on net income from self-employment
• Withholding tax: no withholding obligation for Swiss payers; special rules for foreign payers
• Accounting obligation from CHF 500 000 turnover (CO 957)

Commission as income from self-employment

Anyone who receives affiliate commissions for CRM referrals as a trustee, IT consultant or management consultant earns income from self-employment within the meaning of DBG Art. 18.

Requirements for self-employment:

• Independent, planned activity
• Presence in economic life
• Intention to earn income (profit orientation)
• Own risk and responsibility

In classical fiduciary or consulting activities these criteria are typically met — affiliate commissions complement the existing business and are treated the same for tax purposes.

Distinction from hobby activity: Sporadic, unsystematic referrals without meaningful turnover can be considered a hobby and treated differently for tax purposes. Cantonal tax authorities decide on a case-by-case basis.

Direct federal tax and cantonal tax

Commissions must be declared in the tax return in the business report:

• Direct federal tax (DBS): progressive rate, max. 11.5 %
• Cantonal and municipal tax: highly variable depending on residence
  • Zurich: approx. 21.04 % (top rate)
  • Bern: approx. 18.82 %
  • Lucerne: approx. 11.8 %
  • Zug: approx. 8.2 %
  • Geneva: approx. 23.06 %
• Church tax: additional depending on denomination and canton

Effective overall burden: typically 25–45 % on net income, depending on residence and personal income level.

Practical tip: Optimising residence (e.g. moving to Zug or Schwyz) can be worthwhile for substantial commission volumes — but only if the residence is actually relocated (tax avoidance is strictly scrutinised).

Value-added tax obligation

Commissions from affiliate activity are subject to VAT under the VAT Act. Thresholds:

• Under CHF 100 000 annual turnover: exemption from VAT obligation
• From CHF 100 000: mandatory registration with the FTA
• Standard rate: 8.1 % (since 01.01.2024, previously 7.7 %)
• Reduced rate: 2.6 % (food etc., not for commissions)

Important: The entire annual turnover from self-employment counts towards the threshold — i.e. fiduciary fees PLUS affiliate commissions PLUS other income together.

If you are already VAT-liable as a trustee because the fiduciary fee > CHF 100 000, the commission must automatically also be invoiced on a VAT gross basis.

Example calculation

You are a trustee with CHF 150 000 annual fee (VAT-liable) and additionally receive CHF 20 000 affiliate commission.

• Commission net: CHF 20 000
• VAT 8.1 % on that: CHF 1 620
• Gross invoice to TecArt: CHF 21 620

The VAT of CHF 1 620 must be paid to the FTA in the quarterly return. Input VAT from business expenses (software, phone, conferences) can be deducted.

AHV, IV and EO contributions

Self-employed persons pay social insurance contributions on net income:

• AHV: 8.1 % (as of 2026)
• IV: 1.4 %
• EO: 0.5 %
• Total: 9.75–10 % depending on exact calculation
• Occupational pension (BVG): voluntary but recommended

Contributions are paid directly to the compensation office (Ausgleichskasse) of your canton. For exclusively part-time activities the obligation may not apply.

Withholding tax on foreign commissions

If you receive commissions from a foreign provider (e.g. HubSpot based in the USA), withholding tax may be charged in the country of source:

• USA: 30 % withholding tax, reducible to 0–15 % under the Switzerland–USA DTA
• Estonia (Pipedrive): 0 % on brokerage commission (DTA)
• Germany: 0 % with correct exemption registration
• Other EU states: variable depending on double taxation agreement

Practical tip: With US providers fill out Form W-8BEN to request a reduced tax rate. With DACH providers request an exemption certificate. Consult a specialised tax adviser for complex cases.

Accounting obligation

Under CO 957 ff. there is an accounting and financial reporting obligation depending on turnover:

• Up to CHF 500 000 annual turnover: simplified records ("milk-book accounting") suffice
• From CHF 500 000: proper accounting with balance sheet and income statement
• From CHF 10 million turnover: additional obligations (notes, management report)

Affiliate commissions should be posted to separate revenue accounts — typically in the 6000 series (e.g. 6500 "Affiliate commission revenue").

Practical recommendation: accounting setup

1. Separate revenue account for affiliate commissions
2. Quarterly VAT reporting if liable
3. Archive documents for at least 10 years (CO 958f)
4. Document expense allocation (affiliate vs. fiduciary)
5. Consult tax advice for residence moves or first-time commencement of the activity

Conclusion: Clear rules, professional implementation

Affiliate commissions are clearly regulated for tax purposes in Switzerland: self-employment income, VAT-liable from CHF 100 000, AHV-liable on net income. With proper bookkeeping and correct declaration the risk is low.

It becomes more complex with foreign commissions (withholding tax, DTAs) or residence issues. A specialised tax adviser is worthwhile here.

Important note: This article is general information, not individual tax advice. For specific questions consult a cantonal tax authority or a licensed tax adviser.

Sources

• Direkte Bundessteuer (DBG) — Art. 18
• Mehrwertsteuergesetz (MWSTG)
• AHV-Beitragspflicht selbstständig Erwerbende
• Schweizer Obligationenrecht — Art. CO 957 ff. (Accounting)
• DBA overview FTA, as of 2026