Starting position

The basis for the minimum taxation of large corporate groups was established by the referendum held on 18 June 2023. Only large multinational corporate groups with annual revenues of at least 750 million euros are subject to the new minimum taxation. Ab out 99 % companies in Switzerland are therefore not directly affected by the reform and will continue to be taxed as previously.

The Ordinance on the Minimum Taxation of Large Corporate Groups (MindStV) of 22 December 2023 entered into force on 1 January 2024. As far as Swiss top-up tax is concerned, it applies to financial years starting on or after 1 January 2024.

The Federal Council will decide during the course of 2024 concerning the introduction of the international top-up tax in order to collect the top-up tax according to the primary top-up tax rule (Income Inclusion Rule, IIR) and the secondary top-up tax rule (Undertaxed Payments Rule, UTPR).

The MindStV is applicable for a fixed period of time. Primary legislation will be enacted in due course according to the ordinary procedures.

The implementation of global minimum taxation in the form of the top-up tax and the GloBE Information Return (GIR) are different processes, which are independent from each other.

The system for transmitting the GIR operates independently and as a general rule does not have overlap at all with the top-up tax.

The top-up tax is a federal tax and the cantons are responsible for its implementation.

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Last edition: 20.02.2024