Switzerland and OECD pillar two: Redefining taxes, charges and duties

The G20/OECD project to introduce a global minimum tax level of 15% is taking shape and moving forward fast, and country responses are progressing slowly. 

The Swiss federal government has given the Swiss Federal Tax Administration and the cantonal tax authorities the task of elaborating, in collaboration with interest groups from all Swiss economic sectors, possible Swiss responses. 

The OECD technical guidance on income inclusion rules and undertaxed payments, which will be published later in 2021, must be translated into Swiss law. The Swiss Parliament meanwhile has tasked the government with other tax reforms:

• The global anti-base erosion (GloBE) rules require affected corporations to achieve jurisdictional minimal taxation of 15% in order to avoid a top-up tax. All covered taxes can be counted towards the 15% tax due and ordinary tax rates on affected corporations may need to be increased. Parliament requests that these increases are based on a ‘cost-neutral’ approach for affected corporations. As such, charges and duties, which are not considered covered taxes, should be reduced accordingly.

• Lowering the administrative burden on Swiss corporations with regard to their financing needs, in particular with regard to the abolition of Swiss withholding taxes on all financing issued from Switzerland, enjoys broad-based agreement in Parliament. Legislation is expected to be passed in the course of this year.

• Abolition of Swiss stamp duties is a further proposal that goes beyond the proposed adjustments to Swiss withholding taxes. The related law passed through Parliament in June 2021 and may, unless a referendum is called, enter into force as soon as 2022.

The global tax environment is changing fast and Switzerland is working quickly to innovate its tax landscape and remain attractive. 

Given the broad range of tax reforms and the country’s intention to make the changes to taxes, charges and dues as cost-neutral as possible for corporations, Switzerland remains open for global business.

René Zulauf

Partner, Deloitte Switzerland

E: rzulauf@deloitte.ch

Manuel Angehrn

Senior manager, Deloitte Switzerland

E: maangehrn@deloitte.ch