Facts
Association [X.] is an association within the meaning of Art. 60 et seq. CC, which organises automobile races and promotes motorsports. In the context of a VAT audit for the years 1995 to 2000, the Federal Tax Administration demanded additional VAT in the total amount of CHF 74,889.-- as the association allegedly under-declared its revenues and applied the wrong tax rate. Ultimately, only the additional assessment of CHF 52,030.35 regarding the start and entry fees for drivers domiciled in Switzerland for races abroad remained disputed. The association argued that this constituted a tax-exempt supply (rental of a racetrack), while the tax authorities considered it a taxable service.Considerations
The Federal Supreme Court dismissed the association's appeal. It stated that the services provided by the association in connection with the car races - such as organisation, timing, safety, etc. - are to be qualified as a single service, even if a certain rental component may be included. The decisive factor is that the economic core of the overall service lies in the sporting activity within the framework of the race or training event.…