On 23rd June 2022, the Swiss Federal Council published the amendments to the constitution to implement a minimum tax rate for certain companies recently agreed by the OECD and G20 member states.
In fact, in October 2021, the Organisation for Economic Co-operation and Development (OECD) published key parameters for the future taxation of large, multinational companies. A minimum tax rate of 15% for multinational companies with turnover of more than EUR 750 million has been agreed by 137 countries.
At the beginning of 2022, Switzerland announced a public consultation, the content of which is in line with the updated draft legislation including domestic minimum top-up tax as well as an Income Inclusion Rule and Undertaxed Payment Rule.
The current constitutional amendments will be the basis for an ordinance that will be published in the future, ensuring that the minimum tax rate can come into force on 1 January 2024.
Following this transitional period that will allow to react flexibly to international regulatory developments, the respective law will be enacted.