Switzerland Published Updated Minimum Taxation Ordinance

SDSAD

Although the Federal Council already decided on 4 September 2024 (media release: German/French/English; see also blog) that Switzerland will introduce the international top-up tax under the Income Inclusion Rule (“IIR”) from 1 January 2025, the legal basis in the Swiss Minimum Taxation Ordinance (German/French) has not yet been amended. In today's meeting, the Federal Council has now taken this step and amended the Ordinance (media release: German/French). The following should be noted:

Switzerland will levy the IIR from financial years beginning on or after 1 January 2025. The financial year is regulated in art. 10.1.1 OECD Model Rules and corresponds to the group's financial year. This may be relevant if a group has a financial year that does not correspond to the calendar year.
Furthermore, various linguistic adjustments have been made to the Italian and French versions.
The amended Ordinance will come into force on 1 January 2025. As a result of the Federal Council's decision, the ordinance is considered "enacted" for US GAAP purposes.
In the accompanying report, the Federal Council reiterated that Switzerland will refrain from introducing the international top-up tax under the Undertaxed Profit Rule (UTPR) until further notice.

If you would like to discuss more on this topic, please reach out to our key contacts below.

Key contacts

Thomas Hug - Partner, National Tax Office

Thomas is the leader of Deloitte Switzerland's National Tax Office. He has a proven track record of being at the forefront of international tax developments and analysing their impact from a Swiss tax technical perspective. Thomas has published thought-leading articles and books, and is frequently asked by industry groups, universities and tax and accounting associations to make presentations or lead seminars. He serves as a substitute judge at the Zurich Tax Court of Appeal.

Daniel Stutzmann - Partner, Global Minimum Taxation

Daniel is a Tax Partner with 18 years of experience as an international corporate tax specialist. This includes a one-year assignment in the US to lead the Swiss ICE Desk of Deloitte. He is a specialist in the proposed OECD Pillar 2 legislation and its impact and leads the Deloitte Switzerland Pillar 2 team. In addition, he is co-leading the Deloitte Global Pillar 2 technical advisory group.

Daniel has extensive experience in the area of cross-border structuring (like establishing tax efficient IP- and financing structures) as well as business reorganizations including large supply chain transformation projects. This also includes advising several multinationals in moving their worldwide/regional headquarters or central functions to Switzerland.

As a Swiss tax expert he has managed the Swiss tax compliance of hundreds of companies in Switzerland from various industries. He is well acquainted with the Swiss tax authorities and has successfully led various tax audit and tax ruling negotiations with the Swiss tax authorities. He also has broad knowledge in tax accounting and tax reporting both from an advisory and audit side. Daniel leads the business tax practice in Switzerland.

Manuel Angehrn- Director, Global Minimum Taxation

Manuel is a Director with over 10 years of experience in International Tax. He is a Deloitte Switzerland’s Global Minimum Tax subject matter expert. He follows domestic and global tax developments and assesses the impact to Swiss multinationals.

Comments

Verify your Comment

Previewing your Comment

Posted by: |

This is only a preview. Your comment has not yet been posted.

Your comment could not be posted. Error type:

Your comment has been saved. Comments are moderated and will not appear until approved by the author. Post another comment

The letters and numbers you entered did not match the image. Please try again.

As a final step before posting your comment, enter the letters and numbers you see in the image below. This prevents automated programs from posting comments.

Having trouble reading this image? View an alternate.

Deloitte