OECD Pillar Two – Global minimum tax in Switzerland

The OECD’s Pillar Two framework introduces a global minimum corporate tax rate of 15% and represents a major shift in international tax rules.

Multinational enterprise (MNE) groups operating across multiple jurisdictions must now address new compliance obligations, data requirements and reporting challenges.

Understanding how Pillar Two applies in Switzerland is essential to mitigating risks, ensuring compliance and anticipating financial impacts.

When does Pillar Two apply in Switzerland?

Pillar Two rules are implemented in Switzerland in two phases:

• From 1 January 2024:
  • The Qualified Domestic Minimum Top-up Tax (QDMTT) ensures Swiss entities meet the 15% minimum effective tax rate.
• From 1 January 2025:
  • The Income Inclusion Rule (IIR) applies to further enforce global minimum tax compliance.

Affected groups must register and file declarations via the Swiss Federal Tax Administration’s OMTax platform, with QDMTT filings due by June 2026. Failure to comply may result in penalties of up to CHF 10,000.

Read more about deadlines and requirements from the Swiss Tax Administration.

Who is affected?

Pillar Two applies to multinational enterprise groups with consolidated revenues of at least EUR 750 million, including:

• Swiss headed multinational groups with international operations;
• Swiss subsidiaries of foreign multinational groups.

Both Swiss and non Swiss structures operating in Switzerland may be impacted.

What actions should organisations take now?

Organisations potentially within scope should act proactively to avoid last minute compliance challenges. Key steps typically include:

• Assessing exposure to Pillar Two taxes across jurisdictions;
• Reviewing existing financial reporting and data systems;
• Identifying gaps in effective tax rate calculations;
• Defining a compliance roadmap aligned with Swiss and international requirements;
• Monitoring regulatory developments.

Why choose RSM for Pillar Two readiness?

RSM combines local Swiss tax expertise with the global reach of the RSM network to support multinational groups at every stage of Pillar Two implementation.

Our support includes:

•    Practical guidance on Swiss and international Pillar Two rules;
•    Risk identification and mitigation strategies;
•    Tailored approaches aligned with business objectives;
•    Coordination across jurisdictions through a single point of contact.

Get Pillar Two ready with RSM Switzerland

Speak with our Tax experts to assess your exposure and prepare for compliance.