On December 22, 2023, the Swiss Federal Council issued the ‘Ordinance on the Minimum Taxation of Large Groups’ (the ‘Pillar Two Ordinance’) to introduce the Pillar Two GloBE rules in Switzerland from January 1, 2024.
However, only the domestic top-up tax (intended to be a Qualified Domestic Minimum Top-Up Tax) applies from January 1, 2024. On September 4, 2024, the Swiss Federal Council announced that the Income Inclusion Rule (IIR) will apply from January 1, 2025.
On November 20, 2024, the Swiss Federal Council issued the Amended Minimum Tax Ordinance.
The Amended Ordinance amends Article 40(2) of the Minimum Tax Ordinance to provide for the application of the IIR to financial years beginning on or after January 1, 2025. If the financial year does not correspond to the calendar year, the IIR will apply for the first time to the 2025/2026 financial year.
The UTPR is not yet in effect.
The Amended Ordinance also include various linguistic changes to the French and Italian versions of the Minimum Tax Ordinance.
The Pillar Two Ordinance does not attempt to redraft the OECD Model Rules, instead it transposes the OECD Model Rules into Swiss law by way of a direct static reference in Article 2 of the Pillar Two Ordinance.
For Detailed Information on the application of the GloBE Rules in Switzerland, based on the latest November 2024 Amendment to the Minimum Tax Ordinance, see our:
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