Swiss Parliament approved the implementation of Global Minimum Tax(OECD Pillar II) in a referendum on June 18, 2023.The change is expected to come into effect from January 1, 2024.
- Domestic top-up-tax regime(QDMTT) shall apply to Swiss Constituent entities of an MNE group.
- Income Inclusion Rules (IIR) shall apply to all foreign subsidiaries of a Swiss resident ultimate parent entity, qualifying intermediary holding company, or a partially- owned Swiss parent entity.
- Implementation of Undertaxed Profit Rules (UTPR) is expected by 2025.