Switzerland

Base Erosion and Profit Shifting (BEPS) 2.0 - Pillar Two 

On 5 January 2026, the Organisation for Economic Co-operation and Development (OECD) Inclusive Framework adopted the Side-by-Side Package, introducing five additional safe harbour rules. Switzerland applies these directly on a dynamic basis via the Minimum Taxation Ordinance. Notably, the Side-by-Side Safe Harbour exempts United States (US)-parented multinational enterprise (MNE) groups from the Income Inclusion Rule (IIR) and Undertaxed Profits Rule (UTPR) top-up taxes for tax periods beginning on or after 1 January 2026, while the Swiss Qualified Domestic Minimum Top-up Tax (QDMTT) continues to apply.

The Global Anti-Base Erosion (GloBE) Information Return (GIR) must be filed via the Swiss Federal Tax Administration's (SFTA) ePortal. The first GIR for 2024 calendar year companies is due by 30 June 2026. From 2025 onwards, the filing deadline is 15 months after the end of the tax period. The GIR filing does not replace the supplementary tax return ('Ergänzungssteuererklärung') – both must be filed separately.

Parliamentary motions (adopted in December 2025) requested the Federal Council to amend the Minimum Taxation Ordinance to limit the application of the January 2025 Administrative Guidance to tax benefits granted as of 1 January 2025. Until the Federal Council acts, the Administrative Guidance must be applied; cantonal tax authorities will not issue final assessments for affected cases in the interim.

Net operating losses

The Swiss Parliament adopted the Federal Act on the Extension of the Loss Carryforward Period in December 2025. The referendum deadline expired unused on 17 April 2026. The Federal Council will determine the date of entry into force, at the latest by 1 January 2028. As of that date, the loss carryforward period will be extended from seven to ten years, applicable to tax losses incurred in tax period 2020 and onwards (for losses incurred before tax period 2020, the previous seven-year limitation period continues to apply). The extension applies to direct federal corporate income tax (CIT) and cantonal/communal CIT. A loss carryback concept does not exist in Switzerland.