What does NOV stand for?
NOV – a subsequent ordinary assessment – means that a person liable for withholding tax is subject to an ordinary tax assessment in addition to the withholding tax already deducted. For a person with a B permit and tax residence in Switzerland, this is particularly the case if their gross income from employment amounts to at least CHF 120,000 per year. A NOV may also be issued in the case of additional income not subject to withholding tax or taxable assets, or upon application. The withholding tax already paid is credited against the final tax liability.
In the present Pillar 3a case, it is clear that the obligation to make a NOV contribution and eligibility for Pillar 3a are two separate issues. A person with a B permit and an income of CHF 95,000 may still have been entitled to make contributions to Pillar 3a in the year in question, even without a NOV.
From 2026, it will be possible for the first time to retrospectively close contribution gaps for the year 2025 in Pillar 3a. This provision raises the question, particularly for individuals subject to withholding tax who are subsequently assessed under the standard tax assessment procedure, as to whether a retroactive top-up is only possible if a NOV had already been carried out in the original contribution year.
The answer is: No. Whether a NOV took place in the relevant contribution year is not a determining factor for eligibility for retrospective contributions.
What is decisive, rather, is whether the conditions for contributions to Pillar 3a were met in the relevant year. The Federal Social Insurance Office (FSIO) expressly states that the individual must be eligible for Pillar 3a both in the year of the buy-in and in the year for which the contribution gap is subsequently closed. A key requirement is, in particular, an income from gainful employment in Switzerland that is subject to AHV contributions.
Example:
Ms Fuchs moved to Switzerland on 1 January 2025 and holds a B permit. In 2025 and 2026, she earned an income of CHF 98,000 from employment that is subject to AHV contributions. She is therefore, in principle, entitled to make contributions to Pillar 3a, but is not, in practice, required to submit a tax return.
In 2025 and 2026, Ms Fuchs will none Contributions to Pillar 3a. No application for a standard NOV assessment will be made in these years either.
In 2027, her income rises to CHF 130,000. As a result, she now falls under the NOV scheme and is assessed for tax in the standard manner. In 2027, she opens a Pillar 3a account and immediately pays in the maximum amount of CHF 7,258.
In addition, she can now close the contribution gap from 2025 by making a retrospective contribution. Assuming that the relevant ‘small contribution’ remains at CHF 7,258 in 2027 as well, the following applies:
| Contribution 3a | Amount |
|---|---|
| Ordinary contribution for 2027 | CHF 7,258.00 |
| Subsequent purchase in 2025 | CHF 7,258.00 |
| Total deposit in 2027 | CHF 14,516. |
It is possible to make a retrospective contribution for 2025, even though she did not have a NOV in 2025. The key factor is that Ms Fuchs was already entitled to a Pillar 3a pension in 2025 on the basis of her income from gainful employment subject to AHV contributions, and that this entitlement will also continue in the year of the catch-up contribution, 2027. The new provisions do not make the option to make a catch-up contribution conditional upon having made a NOV in the original contribution year.
Both the standard contribution and the additional contribution can be deducted in full from taxable income in 2027.
What do you need to bear in mind?
Retrospective top-ups are limited to the so-called ‘small contribution’ for the year in which the top-up is made. For employees affiliated to a pension scheme, this amounts to CHF 7,258 for 2025 and 2026.- For any subsequent purchase year, the maximum amount applicable at that time shall apply. Consequently, she cannot simultaneously make up the shortfall from 2026. However, she can do so retrospectively in, for example, 2028 and thus benefit once again from a double deduction.
Conclusion
The absence of a NOV in the original contribution year does not prevent a subsequent buy-in. For the restricted Pillar 3a, the decisive factor is whether the person earned income subject to AHV contributions in the year in question and was therefore, in principle, entitled to Pillar 3a. Whether the person was subject to withholding tax, was assessed in the ordinary tax assessment procedure or did not receive or apply for a tax assessment notice (NOV) in the same year is irrelevant to this requirement.
In practice, this demonstrates once again how important early tax and financial planning is, so that existing opportunities for tax optimisation can be identified and utilised to the full.
The facts of the case and the assessment as described were confirmed by the tax office in 2026.