Switzerland Cabinet Seeks Comments on Draft Amendments to Minimum Taxation Ordinance Under Pillar 2

The Swiss Federal Council May 6 opened a consultation on draft amendments to the Minimum Taxation Ordinance regarding the global minimum tax on multinational enterprise (MNE) groups under OECD Pillar Two. The draft amendments include measures to: 1) apply the OECD administrative guidelines regarding the limited consideration of deferred tax assets in effective tax rate (ETR) calculations during the transitional period under the Global Anti-Base Erosion (GloBE) Model Rules, from fiscal years beginning on or after Jan. 1, 2025; and 2) disallow retroactive adjustments for financial year 2024, to prevent an enforcement deficit due to the additional administrative burden. The ...