OECD Minimum tax (Pillar 2) in Switzerland: current status and upcoming challenges

With Pillar 2 in force since January 2024, Switzerland has entered a new phase in international tax reform. The OECD’s global minimum tax framework seeks to ensure that large multinational groups face a minimum effective tax rate of 15%, regardless of where they operate.

Switzerland has opted for a gradual implementation of the Pillar 2 rules. Yet in an evolving global environment, particularly regarding the United States, companies must remain attentive. The following provides an overview of the current situation.

A gradual but concrete implementation in Switzerland

In June 2023, the legal foundation was laid when Swiss voters approved a constitutional amendment allowing the introduction of Pillar 2 through an ordinance.

This accelerated process enabled the Confederation to meet international timelines without waiting for the passage of a federal law.
Since 1 January 2024, the Qualified Domestic Minimum Top-up Tax (QDMTT) has been in force. This top-up tax applies to groups with consolidated revenues exceeding EUR 750 million and ensures that profits generated in Switzerland are taxed at an effective rate of at least 15%.

The next milestone was reached  on 1 January 2025 with the Income Inclusion Rule (IIR), which allows Switzerland to tax profits from foreign subsidiaries of Swiss companies if those profits are taxed below the minimum 15% rate in the foreign country. 

Switzerland does not plan to implement the third OECD rule, the Undertaxed Profits Rule (UTPR), for the time being. The Federal Council has postponed its introduction until further notice. This rule serves as a backstop where profits are insufficiently taxed in certain jurisdictions.

On the administrative side, the OMTax platform has been available since January 2025 via the Swiss Federal Tax Administration’s ePortal. It enables groups to register, designate the reporting entity, and fulfil new filing obligations. The first QDMTT declarations must be submitted by 30 June 2026.

International consistency under pressure

The main challenge in implementing Pillar 2 lies in international coordination.

While many countries, such as EU Member States and Switzerland,  are progressing steadily, the United States has not adopted the Pillar 2 rules (such as IIR or QDMTT) and officially withdrew from international negotiations in January 2025.

However, the U.S. already has its own minimum tax regimes, notably GILTI (Global Intangible Low-Taxed Income) and BEAT (Base Erosion and Anti-Abuse Tax), both aimed at curbing base erosion and profit shifting.

On 28 June 2025, the G7 proposed a “side-by-side” system that would exempt U.S.-headquartered groups from the Pillar 2 IIR and UTPR rules, recognising the existing U.S. minimum tax framework.

The OECD Secretariat welcomed this proposal as a step towards greater stability in the international tax landscape, though it remains a political agreement pending legislative implementation.

This exemption, however, weakens the principle of a level playing field among global companies and could give U.S. multinationals a competitive advantage, as they would not be subject to the same minimum requirements as their foreign counterparts.

Preparing for practical implementation

While the concept of Pillar 2 is not new, its practical implementation marks a significant administrative and technical shift for affected groups.

It is not merely a question of adjusting tax rates but of integrating new, often complex reporting obligations within a framework that is still partially evolving internationally.

In Switzerland, the rules are now in place and the first deadlines are approaching. It is therefore crucial for multinational groups to identify their GloBE obligations, ensure that they are appropriately structured and prepared for the new requirements in a timely and comprehensive manner.

We are already assisting several groups with the implementation of Pillar 2,  from exposure assessments and OMTax registration to the preparation of upcoming reporting requirements.

If you have questions about your situation or wish to anticipate the next steps, our team is ready to support you.