Federal Council specifies ordinance on minimum taxation of large companies with international reporting obligations
The OECD Minimum Tax applies to substantial multinational corporate groups with yearly revenues of €750 million or above. The OECD minimum taxation rules encompass a reporting requirement for the relevant company groups, referred to as the Global Anti-Base Erosion Model Rules (GloBE) declaration. This is a mandatory report that must be submitted by large companies. The objective is to furnish pertinent tax authorities globally with information regarding the company group’s revenues and whether the taxes have been remitted.
To save groups from having to submit multiple reports, the GloBE agreement was developed at international level to prevent parties from submitting numerous reports by facilitating information exchange regarding minimal taxation. On 12 September 2025, the Federal Council approved the dispatch for the adoption of the GloBE agreement. The matter is presently under deliberation in Swiss Parliament.
Additionally, the Federal Council has amended the ordinance regarding minimal taxation for large groups, as indicated in a press release of the Federal Council. The objective is to clarify the reporting obligations within the context of international information sharing on OECD minimum taxation and to reduce the administrative load on companies through a centralised filing method. The revision to the ordinance specifically governs the filing of declarations to the Federal Tax Administration (FTA), the worldwide exchange of declarations by the FTA, and their use by the cantons. The amendment is set to take effect on 1 January 2026. Companies must submit their initial statements by 30 June 2026 at the latest.
Additional information is available here.