Switzerland: Application of Pillar Two rules to hybrid arbitrage arrangements under CbC reporting safe harbor
Applicable to transactions entered into after December 18, 2023
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