Claiming back withholding tax: The three-year deadline must be strictly adhered to

Anyone wishing to apply for a refund of withholding tax must do so within the statutory period of three years from the due date of the taxable payment.

Late applications will not be processed, even if the taxpayer claims to have been prevented from submitting the application on time by third parties, e.g. trustees, advisors or missing documents.

Conclusion: The responsibility for submitting the refund application on time always lies with the taxpayer themselves; organisational problems or omissions on the part of advisors are not considered valid excuses. (Source: BGE 9C_687/2024 of 25 September 2025)