BEPS 2.0 : Minimum taxation of large corporate Swiss groups (update)

While there was talk of postponing the entry into force in Switzerland of the 15% minimum tax for multinationals (with annual sales in excess of €750 million), the Federal Council has finally confirmed that it will come into force on 1 January 2024, as a result of its decision of 22 December 2023.
 

This change, via a change of the Swiss constitution and federal decree approved by vote in June 2023, temporarily gives the Federal Council the power to introduce this taxation by ordinance. The Council therefore issued the Ordinance on the Minimum Taxation of Large Corporate Groups (OIMin), which has now come into force following its publication in the Official Compendium. (RO 2023 841).

In implementing this minimum taxation, the Federal Council is committed to the following principles:

• Ensure international compatibility, in accordance with OECD and G20 regulations.
• Preserve Switzerland's economic interests by using option rights where possible.
• Limit administrative burdens for companies and cantonal tax administrations.
   

The Federal Council is currently monitoring international developments in this area, and has provisionally decided not to introduce an international supplementary tax (IIR and UTPR rules), and will take a decision if necessary to protect Swiss interests.

For more information on this subject, our RSM experts will be happy to help you. Read our article (Pillar II / BEPS 2.0 : Minimum taxation of large corporate groups in Switzerland) in relation to the subject under discussion.