k-flash audio commentOECD Minimal Tax: Implications of a Potential US Withdrawal for Switzerland
k-flash audio commentOECD Minimal Tax: Implications of a Potential US Withdrawal for Switzerland

The case

Since mid-2025, it has become increasingly clear that the United States intend to withdraw from the OECD minimum tax framework; a final decision is expected by the end of this year.

Source: economiesuisse (German)

The commentary

For Switzerland this development primarily entails greater uncertainty. A unilateral suspension of the minimal tax rules would not ease the burden on Swiss companies as profits taxed at below 15 % would still be subject to top-up taxation abroad resulting in lost revenue for Switzerland. Many cantons have already raised their corporate tax rates, rendering the national top-up tax largely insignificant.

For this reason maintaining legal certainty is crucial. Many companies are already fully compliant with the minimal tax and do not owe additional payments. If Switzerland were to suspend its rules, these companies would have to make extensive efforts to demonstrate compliance abroad, efforts that could be challenged by foreign authorities, potentially leading to additional tax claims or lengthy mutual agreement procedures.

It remains to be seen to what extent a US withdrawal could destabilise the international tax architecture. What is clear, however, is that instead of creating more fairness, a more fragmented global tax landscape could particularly disadvantage highly competitive business locations such as Switzerland.

Despite the minimal tax, Switzerland must take further steps to strengthen its attractiveness as a business location. During the upcoming winter session, various proposals calling for a long-term strategy and targeted investment incentives will be debated. Additional tax incentive measures from the OECD are also expected before the end of the year.

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