Switzerland

On 22 December 2023, the Federal Council decided on Switzerland’s further roadmap for implementing the global minimum tax into domestic law. The entry into force date of the Qualifying Domestic Minimum Top-Up Tax (QDMTT) is set to 1 January 2024 and applies for financial years starting on or after 1 January 2024. The implementation of the other elements of the Pillar Two Rules, i.e. the Income Inclusion Rule (IIR) and the Undertaxed Profits Rule (UTPR), is postponed to a later date but expected for 1 January 2025.