Switzerland Introduces OECD Pillar II Minimum Taxation As Per January 1, 2024

In June 2023, the Swiss public voted in favor of the constitutional basis allowing for the Swiss Federal Council to introduce a transitional legislation implementing the 15% minimal statutory tax rate foreseen by OECD's Pillar II. The Swiss Federal Council enacted the new legislation as per January 1, 2024 introducing a domestic minimum top-up tax (QDMTT) only; the income inclusion rule (IIR) and the undertaxed profits rule (UTPR) are currently not introduced.

General context

The OECD tax rules subjecting large multinational enterprises (the"MNE") to a minimum tax rate of 15% (the"GloBE Rules") will become a new international tax standard as from 2024. It has been politically agreed by over 130 jurisdictions, including Switzerland.