Switzerland: Treatment of residual tax for Pillar Two top-up tax purposes

Guidance from the Federal Tax Administration

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october 14, 2025

The Swiss Federal Tax Administration (FTA) in July 2025 clarified that Swiss business units must treat residual tax on distributions as the applicable tax when calculating their Swiss top-up tax liability under the Pillar Two global minimum taxation rules for multinational groups.


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

Olivier Eichenberger | oeichenberger@kpmg.com

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