Corporate Tax in Tax and Legal blog
- Select a blog category
Through a survey of 300 senior tax and finance leaders across a variety of regions and industries, Deloitte has identified certain tax transformation trends impacting the tax and finance teams of large multi-national enterprises.
First of all, data and cost management are still priorities for heads of tax. However, there is now a clear focus on tax-related systems integrations and the adaptations needed to comply with the changing tax regulatory landscape, driven, in particular, by the OECD Pillar 2 regime.
Also, as technology is evolving quickly and becomes a “must have”, companies are exploring different strategies to access technology capabilities, including through outsourcing,
Finally, technology is also a key capability sought in new tax staff hires, where there is a race for the “unicorn” profiles, combining industry knowledge, tax savviness and data/IT expertise.
On July 3, 2023, the Geneva tax authorities (GTA) published on their website an amendment to the way in which they tax management incentive plans.
The new amendment increases the scope for beneficiaries of management incentive plans to receive benefits in a more tax efficient way.
In the popular vote on 18 June 2023, Swiss voters approved the most extensive change to the Swiss corporate tax system in over a century with a wide majority. With the amendment of the Swiss constitution the Swiss voters have paved the way for the Swiss legislator to introduce the global minimum tax (also referred to as “Pillar II”) in Switzerland.
Pillar II introduces an additional layer of taxation (tax law) to Swiss constituent entities of multinational enterprises in scope of the rules and introduces a corporate group taxation system in Switzerland with a mandatory tax of 15% that is determined under a new tax basis (“GloBE”).
The magnitude of change is significant and will redefine the Swiss corporate tax environment in the years to come.
Created at the end of the 18th century, the Municipal Business Tax (“MBT”) (Taxe Professionnelle Communale) is only levied by the municipalities of the canton of Geneva and covers the gainful commercial activity of legal entities and individuals carried on in the canton.
As countries across the world continue with their efforts to implement the OECD’s global minimum tax (Pillar Two, or GloBE Rules) into domestic law, we see Switzerland is continuing to lay the groundwork for the nation to adopt the rules.
The Swiss implementation journey began in June 2022 with the release of their roadmap to adopt the GloBE Rules. The roadmap intends to apply the income inclusion rule (IIR) and qualified domestic minimum top-up tax (Q/DMTT) as of 1 January 2024.
A referendum is scheduled on 18 June 2023, providing the federal government with the authority to continue with the implementation. As Switzerland continues to move forward, it is crucial for in-scope groups located in Switzerland to understand the financial reporting, disclosure and compliance requirements that are on the horizon. This leaves companies with the short time frame to assess the implications of the rules on the organizations.
We would like to invite you to our OECD Pillar II/GloBE Tax Accounting seminar from Tuesday 9 to Thursday 11 May 2023 in the Deloitte office in Geneva. Over this three half-day workshop series (1pm to 6pm), our team of local tax accounting and Pillar II experts will provide an interactive training taking you from the basics of tax accounting to understanding key considerations of Pillar II.
On 2 February 2023, the OECD/G20 Inclusive Framework on BEPS (inclusive framework) released a package of technical and administrative guidance (“administrative guidance”) related to the 15% global minimum tax on multinational corporations known as Pillar Two (or the global anti-base erosion (“GloBE”) rules). The guidance was agreed by consensus of all 142 countries and jurisdictions in the OECD/G20 inclusive framework and forms part of the “common approach.” Under the common approach, countries are not required to adopt the GloBE rules but, if they choose to do so, they agree to implement and administer the rules in a way that is consistent with the outcomes provided for under the Pillar Two model rules and any subsequent guidance agreed by the inclusive framework.
Deloitte Finance Day 2023 - The colours of finance - design your future capability - 1 June 2023 in Zurich
On Thursday 1 June 2023 in Zurich, Deloitte Finance Day is returning for a second edition. We invite you to experience a unique event to grow your network, share ideas on the future of finance, and hear from industry experts on their journey.
Recent developments, such as the acceleration of the public Country-by-Country Reporting (“CbCR”) obligations by Romania, as well the newly published guidance regarding Pillar II safe harbour rules, have put increasing pressure and scrutiny on Multinational Enterprises’ (“MNEs”) CbCR obligations and will directly affect companies’ tax compliance obligations.