Art. 47 Federal Act of 13 October 1965 on the Withholding Tax (WHTA)

The FTA may require security for taxes, interest, and costs, even if they have not yet been established by a final decision or have not yet become due: a. when the recovery appears to be jeopardized; b. when the taxpayer has no domicile in Switzerland, or when they are making arrangements to abandon their domicile in Switzerland or to be removed from the commercial register; c. when the taxpayer is in default or has repeatedly been in default of payment. The request for security must indicate the legal basis for the guarantee, the amount to be secured, as well as the office receiving the security. If the request for security is based on para. 1, let. a or b, it constitutes a sequestration order pursuant to Art. 274 of the Federal Act of 11 April 1889 on Debt Enforcement and Bankruptcy; opposition to the sequestration order is excluded. Requests for security by the FTA may be appealed to the Federal Administrative Court. An appeal against such decisions does not have a suspensive effect. ...