Switzerland Issues Communications Implementing OECD January 2025 and 2026 Administrative Guidance

Tue, 07 Apr 2026 00:00:00 +0000

The Swiss Federal Tax Administration issued Communications 030-E-2026-f and 031-E-2026-f on April 7, 2026, applying the OECD’s January 2025 and January 2026 Administrative Guidance on the Pillar Two GloBE rules to the Swiss domestic implementation. The Communications adopt the Inclusive Framework’s interpretations of the GloBE rules into Swiss administrative practice for the purposes of the Swiss Qualified Domestic Minimum Top-up Tax and the operation of the IIR and UTPR.

The January 2026 Administrative Guidance includes the Side-by-Side package agreed by the Inclusive Framework on January 5, 2026, which addresses the application of the GloBE rules to US-headquartered MNE groups and recognizes the US tax system as a Qualified Side-by-Side Regime in defined circumstances. Switzerland’s adoption of this guidance brings the Swiss Pillar Two regime into alignment with the latest international consensus and provides administrative certainty for MNE groups with Swiss operations.

Administrative Guidance on CompPress | Transfer Pricing Resources

Switzerland Issues Communications Implementing OECD January 2025 and 2026 Administrative Guidance