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Switzerland Issues Second Consultation on the GloBE Rules

Yesterday, Switzerland issued an updated Draft Decree for the Pillar Two Global Minimum Tax. This follows the previous Draft Decree that was subject to a public consultation. 
 
This Draft Decree provides: 
 
 – An update to some of the previous provisions governing the application of the GloBE Rules in Switzerland (particularly the impact of the OECD Administrative Guidance on the design of the Swiss QDMTT); and 
 
 – Procedural and administrative provisions. 
 
The second Decree is subject to a consultation until September 14, 2023. Both Decrees will then be merged, taking into account the results of the consultation and any further technical requirements of the OECD.
 
Note that, a constitutional amendment is required to implement the GloBE Rules.  

On December 16, 2022, the Swiss parliament approved the draft constitutional amendment for enacting the GloBE rules. 

There will be a public referendum on June 18, 2023 and if approved Switzerland will implement the Pillar Two GloBE rules via the temporary decree of the Federal Council.

Updates to the Application of the GloBE Rules

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Lee Hadnum

Lee is a qualified Chartered Accountant and Chartered Tax Adviser. 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. Lee's books have been recommended by The Times, The Guardian and The Telegraph.

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