The basis for the minimum taxation of large cor-porate groups was established by the referendum held on 18 June 2023.

Only large, multinational corporate groups with annual revenues of at least 750 million euros are subject to the new minimum tax. Around 99 per-cent of companies in Switzerland are not there-fore directly affected by the reform and will con-tinue to be taxed as previously.

Ensuring global minimum taxation and drawing up and transmitting the GloBE Information Return (GIR) are different processes, which are inde-pendent of each other.

It is planned that the first international exchange of the GIR in relation to tax period 2024 will occur by 31 December 2026. Therefore, parent compa-nies of groups domiciled in Switzerland will have to file a GIR with the Federal Tax Administration (FTA) by no later than 30 June 2026. As interna-tional requirements, concerning in particular the XML format, exchange deadlines and data securi-ty, are very similar to those applicable to country-by-country reporting (CbCR), the FTA is planning to model the implementation of the GIR on the CbCR model.

The Ordinance on the Minimum Taxation of Large Corporate Groups (MindStV) of 22 December 2023 came into force on 1 January 2024. The MindStV will be applicable for a limited period of time. An Act will be enacted in due course in the ordinary manner.

As regards the Swiss top-up tax (QDMTT), the MindStV will first apply for the first time to financial years starting on or after 1 January 2024. The international top-up tax according to the In-come Inclusion Rule (IIR) will be introduced on 1 January 2025 for the first time in relation to the 2025 tax period. The Federal Council has decided not to introduce the international top-up tax ac-cording to the Under-Taxed Profits Rule (UTPR) for the time being.

The top-up tax is a federal tax, which is collected by the cantons under the supervision of the FTA.