Switzerland: GloBE reporting regulations adopted by Federal Council
The amendments are scheduled to become effective on January 1, 2026.
The Federal Council on September 12, 2025, announced the adoption of amendments to the Minimum Taxation Ordinance, following a public consultation that closed on August 20, 2025. Read TaxNewsFlash
The changes introduce the GloBE information return (GIR) into Swiss law, setting out how it must be submitted to the Federal Tax Administration and used by the cantons. These amendments aim to facilitate the automatic exchange of GIRs between the Swiss Federal Tax Administration and foreign tax authorities and explain how the cantons can use the information in practice.
The amendments are scheduled to become effective on January 1, 2026. However, due to the Swiss legislative process, Parliamentary debate on the amendments cannot begin until the 2025 winter session or the 2026 spring session. In addition, a referendum is required, with the related period concluding no earlier than autumn 2026. Further clarity on the timeline is expected by the end of 2025. The implementation of these amendments does not affect potential future developments regarding minimum taxation.
It should be noted that Switzerland enacted a temporary ordinance for a qualified domestic minimum top-up tax (QDMTT), effective January 1, 2024. This ordinance was amended in November 2024 to introduce an income inclusion rule (IIR), which entered into force on January 1, 2025.
Read a September 2025 report prepared by the KPMG’s EU Tax Centre