Switzerland: Guidance on treatment of permanent establishments (PEs) under Pillar Two minimum tax rules

Guidance on tax liabilities, procedural obligations, and related responsibilities

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May 7, 2025

The Federal Tax Administration (FTA) on March 18, 2025, released a notice (German) detailing the treatment of business units classified as permanent establishments (PEs) under the domestic Pillar Two minimum tax rules.

The notice elaborates on the legal categorization of these entities under Swiss law, addressing their tax liabilities, procedural obligations, and related responsibilities.
 

For further information, contact a KPMG tax professional in Switzerland:

Olivier Eichenberger | oeichenberger@kpmg.com

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