{"id":100001873,"date":"2020-07-01T16:07:09","date_gmt":"2020-07-01T14:07:09","guid":{"rendered":"https:\/\/swissholdings.ch\/en\/?page_id=100001873"},"modified":"2026-04-09T09:52:23","modified_gmt":"2026-04-09T07:52:23","slug":"taxation","status":"publish","type":"page","link":"https:\/\/swissholdings.ch\/en\/taxation\/","title":{"rendered":"Taxation"},"content":{"rendered":"\t\t
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Motions EATC-S \/ EATC-N \"Ensuring legal certainty in the implementation of the OECD minimum taxation <\/div>
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. <\/div>
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Motions to Strengthen Switzerland's Attractiveness as a Business Location <\/div>
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 \u2013 the global minimum tax \u2013 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.<\/div>
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OECD\/G20 project on the Taxation of the Digital Economy <\/div>
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. <\/div>
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Amendment Protocol to the Agreement between Switzerland and the European Union on the Automatic Exchange of Information (AEOI Agreement)<\/div>
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 \u2013 in particular Article 9 on withholding tax exemptions be-tween associated companies \u2013 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. <\/div>
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Double Taxation Agreement<\/div>
Double taxation agreements are a key pillar of Switzerland\u2019s 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.<\/div>
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International Tax Law <\/i><\/span><\/h3>\n \n<\/div>\n<\/a>\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t\t<\/div>\n\t\t<\/div>\n\t\t\t\t
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National Tax Law <\/i><\/span><\/h3>\n \n<\/div>\n<\/a>\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t\t<\/div>\n\t\t<\/div>\n\t\t\t\t\t<\/div>\n\t\t<\/section>\n\t\t\t\t
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Latest Update in Taxation Department<\/h3>\t\t\t\t\t\t\t\t<\/div>\n\t\t\t\t<\/div>\n\t\t\t\t
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