GloBE Country Guide: Switzerland

Summary

Status	Enacted
Law	On May 6, 2026, Switzerland opened a consultation on amendments to the Swiss Minimum Taxation Ordinance (MindStV). The consultation is a response to two parliamentary motions requiring the Federal Council to delay the Swiss application of the OECD January 2025 Administrative Guidance on Article 9.1 of the GloBE Model Rules for one year, so that the guidance applies only to fiscal years beginning on or after January 1, 2025. On April 7, the Swiss Federal Tax Administration issued Communication-031-E-2026-f and Communication-030-E-2026-f to apply the OECD January 2025 and January 2026 Administrative Guidance. On September 12, 2025, the Swiss Federal Council issued the Federal Decree on the Approval of the Multilateral Agreement of the Competent Authorities on the Exchange of Global Anti-Base Erosion Declarations, which ratifies the OECD GIR MCAA. On April 30, 2025, the Swiss Federal Council issued a proposal to update the Swiss Minimum Tax Ordinance to provide for the OECD provisions relating to the submission of GloBE Information Returns, including the guidance issued in January 2025. The amended Ordinance also updates the application of the OECD Administrative Guidance applied in Switzerland to include the January 2025 OECD Administrative Guidance and the use of the 2025 Consolidated Commentary. This was approved by the Federal Council on November 26, 2025. On December 22, 2023, the Swiss Federal Council issued an Ordinance to apply a QDMTT from January 1, 2024. On September 4, 2024, the Swiss Federal Council announced the application of the IIR from January 1, 2025. On November 20, 2024, the Swiss Federal Council issued the amended Minimum Tax Ordinance to apply the IIR from January 1, 2025
Effective Date	January 1, 2024.
IIR	January 1, 2025 (substantively enacted for IFRS and US GAAP)
UTPR	No
QDMTT	Yes – January 1, 2024
Filing Deadlines	Standard
Safe Harbours	Transposed from OECD Guidance

Access GloBE Country Guide Below

Legislation
General
Differences to Model Rules
Qualifying Domestic Minimum Top-Up Tax
Administration and Filing
Penalties

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Lee Hadnum

Lee is a qualified Chartered Accountant and a former Senior Tax Analyst at Bloomberg Tax. Lee began his career in Ernst & Young's Entrepreneurial Services department and has 20 years of international tax planning experience.

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