Switzerland Gazettes Ordinance Amending Global Minimum Taxation Ordinance Under Pillar 2

The Swiss Official Gazette Dec. 4 published Ordinance No. RO 2025 792, amending the Ordinance on the Minimum Taxation of Large Groups of Companies regarding the OECD Pillar Two global minimum 15 percent tax rate for multinational enterprise (MNE) groups with annual consolidated revenue of at least 750 million euros (US$872 million). The ordinance includes measures: 1) introducing the Global Anti-Base Erosion (GloBE) Model Rules and GloBE Information Return (GIR) filing obligations; 2) requiring central filing of the GIR with the Swiss Federal Tax Administration, with first declaration filings due June 30, 2026; 3) implementing automatic exchanges of GIR declarations ...