The OECD/G20 minimum taxation for large internationally active corporate groups is to be implemented in Switzerland with a supplementary tax. The Swiss electorate will vote on this on June 18, 2023. If this is approved, the Federal Council can introduce the supplementary tax temporarily with an ordinance. At its meeting on May 24, 2023, the Federal Council opened the second consultation on this ordinance.
By implementing the OECD/G20 minimum taxation, the Federal Council and Parliament want to secure stable framework conditions as well as jobs and tax revenues in Switzerland. The new constitutional provision gives the Federal Council the authority to temporarily introduce a supplementary tax by means of an ordinance to ensure this minimum taxation. Within six years, it must submit a law to parliament to replace the ordinance.
In an initial consultation on this so-called Minimum Tax Ordinance (MindStV), it was stated that the model regulations drawn up by the OECD/G20 should be adopted by means of a reference. This will ensure the international compatibility of the Swiss regulations. At its meeting on May 24, 2023, the Federal Council opened the consultation on further provisions of the ordinance, which in particular clarify the tax procedure in Switzerland.
To levy the new supplementary tax, the Federal Council is planning a so-called one-stop store: The economically most significant unit of a corporate group is to pay the tax for all units in Switzerland in its canton. The canton will transfer its share of the supplementary tax revenue to the federal government and to those cantons that are home to other business units of the same corporate group.
The MindStV is expected to enter into force on January 1, 2024. The consultation period will last until September 14, 2023.
Further information and documents are available here.
