Taxation

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 applica-tion of the OECD guidance of 15 January 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. Should Switzerland, as called for by the motion, refrain from applying the taxation prescribed by the aforementioned guidance through the Swiss supplementary tax (QDMTT), there is a risk of losing the qualified status of the minimum tax, with significant consequences such as double taxation and increased administrative burdens for affected companies. Swiss-Holdings 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
The OECD/G20 project on the taxation of the digital economy comprises a profit redistribution mechanism (Pillar 1) and the introduction of a global minimum tax of 15% for large corpora-tions (Pillar 2). Whilst Pillar 1 remains stalled, Pillar 2 – the global minimum tax – has already been implemented by various countries, including Switzerland. In January 2026, the OECD pub-lished the so-called Side-by-Side Package, which effectively exempts US companies from the OECD minimum tax through the recognition of the American system. Among other things, the package also includes OECD-compliant tax relief on labour costs and investments. Swiss Holdings is committed to ensuring that Switzerland takes measures as quickly as possible to make use of the new opportunities to strengthen its own attractiveness as a business location.
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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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Amendment Protocol to the Agreement between Switzerland and the European Union on the Automatic Exchange of Information (AEOI Agreement)
The automatic exchange of information (AEOI) between Switzerland and the EU will be aligned with the revised OECD standard by means of an amending protocol, whilst the existing provi-sions – in particular Article 9 on withholding tax exemptions be-tween associated companies – will remain unchanged. Article 9 is a key location factor for many internationally active Swiss industrial and service companies when considering Switzerland as a location for their headquarters, research, development, IP and financing. The consultation ran until 6 February 2026. SwissHold-ings submitted a response and supports the ratification of the protocol amending the AEOI agreement with the EU.
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Double Taxation Agreement
Double taxation agreements are a key pillar of Switzerland’s in-ternational investment policy. They prevent double taxation, provide legal certainty and facilitate cross-border investment. Agreements with Croatia, Belgium and Zimbabwe are currently under consideration by parliament. SwissHoldings expressly supports the strategic expansion and modernisation of the network of double taxation agreements.
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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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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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