Top-up Tax
In the context of the OECD/G20 minimum taxation, Switzerland levies a top-up tax to compensate for the difference between the effective tax rate and the minimum tax rate of 15%. This affects multinational corporate groups with a consolidated annual turnover of at least 750 million Euros. You will find information related to the declaration as well as technical information here.
In Switzerland, this minimum taxation will be implemented by means of an ordinance. The necessary constitutional amendment was approved by the people and the cantons in a referendum held on 18 June 2023. Within six years, the Federal Council has to submit a federal law to the parliament to replace the ordinance.
At its meeting on 4 September 2024 the Federal Council decided to bring the so-called Income Inclusion Rule (IIR) into force as of 1 January 2025. This international Top-up Tax extends the Swiss Top-up Tax (QDMTT) that was already introduced in 2024.
Top-up Tax declaration
Declare the Top-up tax via the federal ePortal, where you can also register and deregister yourself.
Technical information Top-up Tax
The technical information includes the regulation, OECD publications and practice statements on minimum taxation.
Communications
Read the valid AFC communiqués here.
News
Top-up tax: temporal application and exercise of elections of the administrative guidance of 5 January 2026 on the Side-by-Side Package
The FTA provides information on the effective date of the new safe harbor rules in the context of the minimum taxation of large multinational corporate groups. With regard to the applicable accounting standard for the Simplified ETR Safe Harbor, reference is made to Article 9 paragraphs 2 and 3 of the Minimum Taxation Ordinance (OMinT).
Top-up tax: application of the administrative guidance on Article 9.1 of the Global Anti-Base Erosion Model Rules adopted on 13 January 2025
In the context of the minimum taxation of large multinational corporate groups, the FTA provides information on the application of the administrative guidance on Article 9.1 of the Global Anti-Base Erosion Model Rules adopted on 13 January 2025 in connection with two adopted motions of identical wording. The FTA clarifies that the administrative guidance and the Grace Period Limitation set out therein must be applied pursuant to applicable law and until the Federal Council decides on a possible amendment to the OMinT, and establishes how the declaration for the relevant top-up tax returns is to be made.
Contact
If you have any questions, please contact us using the contact form.
Federal Tax Administration FTA
Main Division DAS
Eigerstrasse 65
3003 Berne