Switzerland: Application of Pillar Two rules to hybrid arbitrage arrangements under CbC reporting safe harbor

Applicable to transactions entered into after December 18, 2023

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november 11, 2025

The Swiss Federal Tax Administration (FTA) in August 2025 issued Communication-027-E-2025-e, regarding the application of Chapter 2.6 of the OECD's December 18, 2023, Pillar Two administrative guidance to hybrid arbitrage arrangements under the transitional country-by-country (CbC) reporting safe harbor.

The guidance applies to transactions entered into after December 18, 2023.


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

Olivier Eichenberger | oeichenberger@kpmg.com

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