Global Minimum Taxation Is Coming

As of January 1, 2024, the provisions of the global minimum taxation will probably also apply to Swiss companies.

Implementation of the reallocation of taxation rights to market states (Pillar One) and the global minimum tax (Pillar Two) made great progress in 2022. While the timing of Pillar One's introduction is still uncertain, as is the question of whether it will be introduced at all, Pillar Two will very likely come into force in the EU, Switzerland and other countries from January 1, 2024. At the end of 2022, the Organization for Economic Cooperation and Development (OECD) published so-called "Safe Harbour Rules" which provide, in particular, for substantial relief for corporations in certain cases. In February 2023, they published the "Administrative Guidance", which provided companies and tax authorities with further clarification on the implementation of the minimum tax. In addition, the Swiss Parliament approved the procedure proposed by the Federal