The case
In 2024, Switzerland implemented the OECD minimum tax for large multinational corporations.
Source: HSG & Swiss Press (NZZ) & Flash, 30 January 2025 *
The commentary
A recent study by the University of St. Gallen (HSG) has since triggered a lively debate. The Institute of Law and Economics, led by Peter Hongler, argues that Switzerland should reconsider its participation in the OECD minimum tax framework and consider withdrawing from it altogether. The study was commissioned by the Swiss American Chamber of Commerce.
Business associations such as the Swiss American Chamber of Commerce support this position. They warn that Switzerland risks losing its attractiveness as a business location and could face the relocation of multinational companies, particularly as long as major economies such as the United States have not fully implemented the OECD rules.
At the same time, other business groups and tax experts advise caution, arguing that a unilateral withdrawal by Switzerland could create significant administrative burdens and tax complexities for internationally active companies if key trading partners continue to apply the minimum tax regime. Major consulting firms, including Deloitte Switzerland, also continue to assume that the OECD minimum tax will remain a relevant feature of the international tax landscape for the foreseeable future and that companies will need to adapt accordingly.
The debate is far from settled and is expected to remain high up both on the political as well as the economic agenda in Switzerland. Given the complexity of the international tax environment, there is no easy fix.
To make matters worse, the OECD is continually ‘refining’ and ‘improving’ the basis on which reporting is conducted: On 18 May 2026, the OECD published details of a “common understanding” reached by the majority of jurisdictions implementing Pillar Two in FY24. This primarily addresses situations in which automatic exchange mechanisms for GloBE Information Returns (GIRs) are not yet in place between jurisdictions, potentially resulting in duplicate local GIR filing obligations. (PWC/UK)
