Switzerland Tax Agency Clarifies Applicability of Side-by-Side Package Regarding Pillar 2 Global Minimum Tax

The Swiss Federal Tax Administration April 7 clarified the applicability of the Pillar Two side-by-side package regarding the global minimum tax, as adopted by the OECD Inclusive Framework. The clarification includes: 1) the introduction of side-by-side and ultimate parent entity safe harbors, applicable for financial years beginning on or after Jan. 1, based on jurisdictions listed in the central record; 2) an extension of the transitional country-by-country reporting (CbCR) safe harbor for qualifying financial years beginning by Dec. 31, 2027, and ending by June 30, 2029, subject to the once-out-always-out rule; 3) the provision of a substance-based tax incentive safe ...