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

Awards
ITR is delighted to reveal the first shortlisted nominees for the Middle East Tax Awards
US President Donald Trump’s tariffs may get thrown out by courts in the future and taxpayers should already be planning for that possibility, BDO’s Dustin Stamper tells ITR
The firm has appointed Deloitte’s former tax leader for Thailand to lead the new operation, which builds on considerable Asian investment in recent months
The Donald Trump administration could use legislation from 1930 if the Supreme Court blocks its tariffs; in other news, China has updated its VAT refund procedures
Braun gives ITR an exclusive insight into WTS Digital’s UK launch of its AI product, which can free up more than 1,500 hours per month by reducing routine tasks
Long tells ITR about her varied role, why curiosity is a key characteristic for the tax professional, and what she’d be doing if she wasn’t working in tax
The choice facing governments is not whether to adopt AI in taxation, but how to do so in a way that upholds the principles of tax fairness, writes Neil Kelley
As ITR’s client data reveals discontent with German tax advisers’ cost management, Grant Thornton’s local TP head insists it’s a two-way street
Uncertainty isn’t always a bad thing, but it’s easy to see how the Trump administration’s IRS commissioner merry-go-round may serve to undermine business confidence
The EU defended its ‘sovereign right’ to impose the tax in the face of US tariff threats; in other news, the US deputy Treasury secretary resigned after just five months
Gift this article