Pillar Two in Switzerland
Switzerland has implemented OECD Pillar Two through Ordonnance sur l'imposition minimale des grands groupes d'entreprises (RS 642.161). Each applies to fiscal years beginning on or after the respective date: the IIR from 2025-01-01, the QDMTT from 2024-01-01.
Implementation Timeline
Each rule applies to fiscal years beginning on or after the date shown.
Quick reference
| Rule | Effective date | Status |
|---|---|---|
| IIR — Income Inclusion Rule | Fiscal years beginning on or after 2025-01-01 | In force OECD qualified |
| UTPR — Undertaxed Profits Rule | — | Not adopted |
| QDMTT — Qualified Domestic Minimum Top-up Tax | Fiscal years beginning on or after 2024-01-01 | In force OECD qualified |
| QDMTT Safe Harbour | Available alongside the QDMTT | Case-by-case |
Implementing legislation
- Ordonnance sur l'imposition minimale des grands groupes d'entreprises (RS 642.161) — 2023-12-22 adopted. France어·Germany어·Italy어 simultaneously promulgated
- QDMTT — 2024-01-01 in force (선행 introduction)
- IIR — 2025-01-01 in force from fiscal years beginning on or after the date shown
- UTPR — not yet announced
Practical implications
MNE groups parented in Switzerland are subject to the IIR for fiscal years beginning on or after 2025-01-01. Where a subsidiary's jurisdictional effective tax rate (ETR) falls below 15%, top-up tax is computed and paid in Switzerland (as the jurisdiction of the parent entities), and the group must also file the GloBE Information Return (GIR).
MNE groups with constituent entities in Switzerland are subject to Switzerland's QDMTT for fiscal years beginning on or after 2024-01-01. Where the conditions of the QDMTT Safe Harbour are met, the IIR/UTPR computation at the parent jurisdictions may be exempted, reducing the burden of dual computation.
Recent legislative developments
- 2023-12-22: RS 642.161 adopted — QDMTT 우선 in force (2024-01-01)
- 2024: IIR in force 시점 확정 (2025-01-01)
Related terms
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- OECD Inclusive Framework — Updated Central Record for Purposes of the Global Minimum Tax, approved 2026-05-11 (current as at 2026-05-01). OECD Global Minimum Tax
- Eidgenössische Steuerverwaltung (ESTV, Switzerland Federal Tax Authority) — Pillar Two guidance. www.estv.admin.ch
- Fedlex — Switzerland official legislation database — RS 642.161. www.fedlex.admin.ch
Disclaimer
This page is reference information prepared as of 2026-05-28 by synthesising the primary sources listed above, and is not legal or tax advice. Before applying any of this material in practice, please:
- Verify the latest legislation, administrative guidance, and tax authority notices
- Obtain review by a qualified Pillar Two specialist
- Reassess applicability against the specific facts and circumstances of the group
Translation note. The authoritative version of this page is the Korean original (국가별 현황 › 스위스). This English version is provided for accessibility and may not capture every nuance of the original sources. Where precision matters, please refer to the Korean original or to the source legislation in its original language.