Switzerland

BEPS 2.0 – Pillar Two 

During its meeting on 4 September 2024, the Federal Council decided to bring the Income Inclusion Rule (IIR) into force with effect from 1 January 2025. This international supplementary tax will complement the Qualifying Domestic Minimum Top-Up Tax (QDMTT) already introduced on 1 January 2024. The implementation of the other elements of the Pillar Two Rules, i.e., the Undertaxed Profits Rule (UTPR), was postponed to a later date. 

Revision of Value Added Tax Act and Ordinance 

The Federal Council implemented the partial revision of the Value Added Tax Act (VAT Act) in August 2024, which was passed by Parliament in June 2023, and will enter into effect on 1 January 2025. At the same time, the partially revised Value Added Tax Ordinance (VAT Ordinance) will enter into effect as well. The partially revised VAT Ordinance includes both the implementing provisions for the amended VAT Act and independent adjustments, particularly concerning the net tax and flat tax rate method as well as portal obligations. Further changes are postponed to 1 January 2027, i.e., the portal obligation for the areas of net tax rate as well as flat tax rate method, group taxation, and deregistration as a taxable person.