At its meeting on November 26, 2025, the Federal Council amended the Ordinance on the Minimum Taxation of Large Corporate Groups. This clarifies the reporting obligation in the context of the international exchange of information regarding OECD minimum taxation and reduces the administrative burden for companies thanks to a central submission.
Specifically, the amendment to the ordinance regulates the submission of the declaration to the Federal Tax Administration (FTA), the international exchange of declarations by the FTA and their use by the cantons. The amendment is to enter into force on January 1, 2026. Companies will submit the first declaration by June 30, 2026 at the latest.
The Minimum Tax Ordinance was amended in other respects: (i) it clarifies the procedure for the international supplementary tax IIR if no subsidiaries abroad are under-taxed in the financial year in question; and (ii) it provides for the allocation of income from the supplementary tax if a business unit changes canton during the year.
The press release with further information (incl. enclosures) can be downloaded here .
