The case

The Federal Council has decided on the second phase of the implementation of the global minimum tax in Switzerland, which was developed as part of the OECD initiative to introduce a minimum tax of 15 % for large international corporations.

The commentary

This regulation affects companies with a worldwide annual turnover of at least € 750 million (approx CHF 700 million).

The minimum tax will be supplemented by the additional tax as of 2025 in order to ensure that Swiss groups such as Nestlé and Novartis, which may be taxed below the 15 % threshold abroad, make up the difference with a tax at home. The aim of this measure is to prevent other countries from benefiting from under-taxation and keeping the tax revenue in Switzerland instead.

According to a rough estimate by the federal government, the additional tax could generate annual revenue of around CHF 500 million to CHF 1 billion. The federal government would obtain a quarter of this sum, with the remainder going to the cantons.

As things stand at present, a good 40 countries have been implementing the global minimum tax and also provide for cross-border set-off taxes.

 

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