Thirds of goods are not always permissible

A company capitalised its services provided to customers in December 2019 but not invoiced until January 2020 in the account “Work in progress” at acquisition or production cost, deducting on third of the value (‘Warendrittel’).

The tax authority did not accept this and demanded that the service be recorded as revenue at the full net sales price. The Federal Supreme Court ruled in favour of the tax authority, as the supplies concerned were standard materials and transport services that could have been invoiced immediately and were thus to be regarded as having been rendered and the consideration owed on the balance sheet date. (Source: BGE 2C_632/2022 of 13.9.22)