Kernrechtsfrage
Whether storage of gold reserves by foreign central banks is a taxable service import subject to Swiss VAT at the recipient's seat.
Extrahierter Entscheid
Yes. The storage qualifies as a taxable financial/depot-related service; the recipient-location rule applies, so VAT is due in Switzerland because the SNB has its seat there.
Extrahierte Begründung
Under the applicable rules, services of asset managers and, more broadly, banking/financial transactions are taxed at the recipient's seat, except for safe-deposit box rental. The Court treated the foreign storage as a depot-related financial service and relied on administrative practice confirming that even sealed deposits are taxable asset management.