Switzerland Cabinet Approves Draft Decree on Information Exchanges Under Pillar 2 Global Minimum Tax

Sept. 18, 2025, 5:00 AM UTC

The Swiss Federal Council Sept. 12 approved a draft decree regarding the automatic exchange of information (AEOI) for the global minimum tax on large multinational enterprise (MNE) groups under OECD Pillar Two. The draft decree includes measures to: 1) ratify the Multilateral Competent Authority Agreement (MCAA) for the exchange of Global Anti-Base Erosion Declarations (GloBE Agreement); 2) implement minimum taxation rules under Pillar Two, including the qualified domestic minimum top-up tax (QDMTT) and income inclusion rule (IIR); 3) establish confidentiality and data protection safeguards for exchanged information; and 4) authorize the Federal Council to determine and update partner country lists ...

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