🇨🇭 Tax1 Jan 2024
Switzerland's 15% minimum tax for large groups takes effect
Switzerland's national supplementary tax, a qualified domestic minimum top-up tax under the OECD's Pillar Two rules, took effect on 1 January 2024. It tops up the tax of Swiss entities of groups with consolidated revenue of at least EUR 750 million to an effective 15%. The Federal Council adopted the Minimum Tax Ordinance on 22 December 2023 under a constitutional amendment approved by voters in June 2023.
Swiss voters approved a constitutional amendment allowing the minimum tax on 18 June 2023, with 78.5% in favour. The Federal Council then implemented it by ordinance.
What changed
- A national supplementary tax applies from 1 January 2024 to Swiss entities of groups with revenue of at least EUR 750 million in two of the previous four years.
- It tops up their effective tax rate to 15%, following the OECD GloBE model rules.
- The cantons assess and collect it. They keep 75% of the revenue and the Confederation 25%.
- The ordinance is temporary: the Federal Council must put a federal act to Parliament within six years.
- The income inclusion rule and undertaxed profits rule were not brought in at first.
Who is affected
Swiss entities of large groups and their tax teams.
Later developments
In September 2024 the Federal Council decided to apply the income inclusion rule from 2025. See our coverage.