Switzerland looks to remain competitive under global minimal taxation

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2025

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Switzerland looks to remain competitive under global minimal taxation

Sponsored by

Sponsored_Firms_deloitte.png
Switzerland will introduce income inclusion rules

René Zulauf and Manuel Angehrn of Deloitte Switzerland explain why the country prefers a multilateral solution to tackling questions on minimum taxation.

On July 1 2021, the OECD agreed on the general outline of an inclusive framework with regards to the future taxation of multinational enterprises. Switzerland, home of many multinational companies and one of the most competitive countries for attracting multinationals, supports the OECD framework.

Switzerland much prefers a multilateral solution on a global scale in this question, to a myriad of uncoordinated attempts by individual countries to tackle minimum taxation with unilateral legislation. A global solution on an OECD level will provide much needed certainty and stability, a key element to enable businesses to plan, innovate and grow.

While only a handful of Swiss based multinationals will likely be affected by OECD pillar one (taxation of large multinationals where the income is generated), OECD pillar two (minimum taxation of 15%) will impact Swiss subsidiaries of foreign multinationals on a broader scale.

A large number of Swiss cantons currently offer headline tax rates (effective federal/cantonal/communal tax rates) below 15%, some of which are below 12%. Indeed, inter-cantonal tax competition within Switzerland, where cantons compete for taxpayers with hard factors, such as low tax rates, and even more so with soft factors (applying a more business friendly, more reasonable approach on all questions of taxation) is the key element that ensures the most competitive tax environment possible.

Although a minimum tax of 15% marginally narrows the differences in tax rates, the competitive spirit will remain that ensures Switzerland will continue to offer a very attractive tax environment for multinationals and keep its competitive edge internationally.

The OECD and G20 members have committed themselves to a swift implementation of the inclusive framework with a targeted ratification and incorporation into domestic legislation by 2023. Anticipating the current momentum of the global commitment, the Swiss federal government has been assessing domestic legislation since late 2019 and intends to publish its legislative agenda and domestic implementation plan in early 2022, once more technical details have emerged from the OECD working groups and after consultation with cantons, political parties and interest groups.

Based on current discussions, Switzerland will introduce income inclusion rules to provide its domestic ultimate parent entities (UPE) with an efficient administrative procedure for compliance with the pillar two framework. The government is further reviewing its possibilities within the inclusive framework and accepted global standards to compensate businesses for the increased income tax burden from the 15% minimum tax. This includes measures such as the planned abolishment of the 1% capital issuance tax on equity contributions, an example of likely many to follow of how Switzerland will ensure to remain a very enticing jurisdiction for multinational companies.

 

René Zulauf

Partner, Deloitte Switzerland

E: rzulauf@deloitte.ch

  

 

Manuel Angehrn

Senior Manager, Deloitte Switzerland

E: maangehrn@deloitte.ch

 

more across site & shared bottom lb ros

More from across our site

Luxembourg’s reform agenda continues at pace in 2025, with targeted measures for start-ups and alternative investment funds
Veteran Elizabeth Arrendale will lead the new advisory practice, which will support clients with M&A tax structuring, post-deal integration, and more
MAP cases keep increasing, and cases closed aren’t keeping pace with the number started, the OECD’s Sriram Govind also told an ITR summit
Nobody likes paperwork or paying money, but the assertion that legal accreditation doesn’t offer value to firms and clients alike is false
Ryan hopes the buyout will help it expand into Asia and the Middle East; in other news, three German finance ministers have called for a suspension of pillar two
SKAT, which was represented by Pinsent Masons, had accused Sanjay Shah and other defendants of fraudulent dividend tax refund claims
TP managers must be able to explain technical issues in simple terms, ITR’s European Transfer Pricing Forum heard
Prudential had challenged HMRC over VAT group relief; in other news, Donald Trump unveiled timber and wood tariffs, and the European Commission published a ViDA implementation strategy
Australia’s CbCR rules have ‘widespread support’ and do not put American companies at a competitive disadvantage, the FACT Coalition said
Baker McKenzie advised two of the member firms involved, while several advisers provided transaction counsel to US-based Grant Thornton Advisors
Gift this article