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.
Declare the Top-up Tax via the federal e-portal, where you can also register and deregister yourself. If you have any questions about registering, deregistering and declaring the Top-up Tax, please contact the tax administration of the relevant canton.
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