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 January 15, 2025, regarding 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. SwissHoldings points out the risk of losing the qualified status for the minimum tax, which would entail signifi-cant risks such as double taxation and increased administrative burdens for affected companies. The consultation draft takes this into account. Therefore, SwissHoldings supports the pro-posed implementation.
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Motions to Strengthen Switzerland's Attractiveness as a Business Location
Three motions, each of which was submitted to both chambers, aim to strengthen Switzerland’s attractiveness as a business location. The motions from the two EATCs(25.4393 and 25.4400) as well as a motion by Councillor of States Mühlemann (25.4265) were adopted by both chambers and referred to the Federal Council. The motion Mühlemann (25.4264) was rejected by the National Council. The two Silberschmidt motions (identical to the Mühlemann motions) were adopted by the National Council and are expected to be debated by the EATC-S on August 31. Swiss-Holdings expressly welcomes the motions. In particular, the substance-based tax incentives—which have recently been approved by the OECD as compliant with minimum tax requirements—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 includes a profit redistribution mechanism (Pillar 1) and the introduction of a 15% global minimum tax for large corporations (Pillar 2). While Pillar 1 remains stalled, 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 U.S. companies from the OECD minimum tax by recognizing the U.S. system. Among other things, the package also includes OECD-compliant tax relief on labor costs and investments. SwissHold-ings is advocating for Switzerland to take measures as quickly as possible so that it can take advantage of these new opportunities 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 is being aligned with the revised OECD Standard through a Protocol of Amendment, while the existing provisions – in particular Article 9 on withholding tax exemptions between affiliated companies – remain unchanged. Article 9 is a key loca-tion factor for many internationally active Swiss industrial and service companies when choosing Switzerland as a location for their headquarters, research, development, IP, and financing. The Federal Council published the dispatch on the agreement on June 24, 2026. SwissHoldings had previously submitted a statement and supports the ratification of the amendment protocol to the AEOI Agreement with the EU.
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Double Taxation Agreement
Double taxation agreements are a central pillar of Switzerland’s international investment policy. They prevent double taxation, provide legal certainty, and facilitate cross-border investment. The treaty with Zimbabwe is currently under parliamentary re-view. SwissHoldings expressly supports the strategic expansion and modernization of the DTA network.
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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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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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