Switzerland: Implementation of Pillar Two minimum tax approved by public vote

Federal Council now allowed to adopt respective GloBE rules and domestic top-up tax

Federal Council now allowed to adopt respective GloBE rules and domestic top-up tax

Swiss voters on 18 June 2023 approved implementing the global minimum tax in Switzerland. The Federal Council is now allowed to adopt respective global anti-base erosion (GloBE) rules and the domestic top-up tax within an implementation ordinance. 


Switzerland is in the process of implementing the global minimum taxation (Pillar Two) agreed by the OECD/G20 Inclusive Framework. To do so, Switzerland’s constitution needs to be amended. 

Latest update

The Swiss public on 18 June 2023 voted in favor of an amendment of the constitution including temporary arrangements with basic parameters that allow the government to release the respective (temporary) implementing ordinance. How the government intends to issue such an ordinance was specified in May 2023 in an amended draft of the implementation ordinance.

Next steps

With acceptance from the public vote, the Federal Council can now go ahead and implement minimum taxation in Switzerland.

The domestic top-up tax and the income inclusion rule (IIR) are expected to be introduced in Switzerland for financial years beginning on or after 1 January 2024 (or even 31 December 2023 to be in line with the EU).

The date for the introduction of the undertaxed profits rule (UTPR) is likely to be different, following international developments. It is becoming apparent that the UTPR will be introduced by a large number of states, in particular in the EU, at a later point in time. It is anticipated that the UTPR will be introduced for business years beginning on or after 1 January 2025 (or 31 December 2024) as provided for by many states. 

Read a June 2023 report prepared by the KPMG member firm in Switzerland



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