Taxation

Extension of Loss Carry-Forward
The federal law on extending loss carry-forwards extends the period for loss carry-forwards from seven to ten years. The regulation is to apply retroactively from the 2020 tax year. The aim is to strengthen economic resilience and give companies more flexibility after crises. The Council of States approved the bill in the winter session as the second chamber, and the matter was adopted in the final vote. SwissHoldings expressly supports the extension. In view of increasing uncertainties, a seven-year carry-forward period is no longer appropriate.
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Motions EATC-S / EATC-N "Ensuring legal certainty in the implementation of the OECD minimum taxation
Motions 25.4392 and 25.4399 call for a time limit on the application of the OECD guideline of January 15, 2025, on Article 9.1 of the GloBE model rules. The motions were adopted by both chambers during the winter session and thus referred to the Federal Council. If Switzerland were to waive the taxation prescribed by the aforementioned guideline by means of a Swiss supplementary tax (QDMTT), as demanded by the motion, it would risk losing its qualified minimum tax status, with considerable risks such as double taxation and increased administrative costs for the companies affected. SwissHoldings therefore rejected the motions and is now advocating for a measured implementation.
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Motions to Strengthen Switzerland's Attractiveness as a Business Location
Various identical motions were submitted in both chambers (25.4192 and 25.4264, 25.4191 and 25.4265, and 25.4393 and 25.4400) with the aim of strengthening Switzerland's attractiveness as a business location. All motions except 25.4400 were debated and adopted by the first chamber during the last winter session. SwissHoldings welcomes the motions and the associated examination of new instruments to strengthen Switzerland's attractiveness as a business location. In particular, the substance-based tax incentives newly approved by the OECD should be examined more closely.
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OECD/G20 project on the Taxation of the Digital Economy
The OECD/G20 project on the taxation of the digital economy comprises a profit redistribution (Pillar 1) and the introduction of a global minimum tax of 15% for large corporations (Pillar 2). While Pillar 1 is blocked, Pillar 2, the global minimum tax, has already been implemented by various countries, including Switzerland. In January 2026, the OECD published the so-called Side-by-Side Package, which effectively exempts US companies from the OECD minimum tax by recognizing the American system. Among other things, the package also includes OECD-compliant tax relief on labor costs and investments. SwissHoldings is committed to ensuring that Switzerland examines how it can use this to strengthen its own attractiveness as a business location.
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Editorials

OECD Publishes Side-by-Side Package and Creates New Opportunities for Switzerland

This is an automated translation. With the Side-by-Side package, the OECD is strengthening the minimum taxation while offering new...

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Editorials

Motions on OECD Minimum Taxation Pose Significant Risks for Swiss Companies

The Council of States has approved the motion on “Legal certainty in the implementation of the OECD minimum tax,” after the National...

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Editorials

OECD Minimum Tax: How Donald Trump Is Rewriting the Global Tax Architecture – and How Europe Can Respond

The United States under President Trump is taking a step back from the consensus on the OECD minimum tax and is pursuing its own rules....

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Editorials

Underrated, but indispensable for international business: Double Taxation Agreements

Switzerland has currently signed double taxation agreements with over 100 countries. This network is constantly being renewed and expanded....

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Press releases

Tax Talks 2024: The minimum tax changes the competition between locations in the long term – what does this mean for Switzerland?

The OECD minimum taxation should ensure that multinational companies pay at least 15% tax on their profits. In Europe, implementation is...

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International Tax Law

Federal Council decides to introduce the OECD minimum tax in 2024

SwissHoldings notes with great concern the Federal Council’s decision to introduce the OECD minimum tax in 2024. The decision is not...

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Contact

Martin Hess

Head Tax Policy, Member of the Executive Committee

+41 31 356 68 61
martin.hess@swissholdings.ch

Claudiu Antal

Deputy Head Tax Policy

+41 31 356 68 69
claudiu.antal@swissholdings.ch

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