Switzerland

On 22 December 2023, the Federal Council decided on Switzerland’s further roadmap for implementing the global minimum tax into domestic law. The Qualifying Domestic Minimum Top-Up Tax (QDMTT) entered into force on1 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), was postponed to a later date, but is expected for 1 January 2025.