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The Federal Council on April 30, 2025, issued a  on amending the Pillar Two minimum tax rules to incorporate the global anti-base erosion (GloBE) information return (GIR).

• Under the proposed rules, only a single constituent entity in Switzerland would be required to submit the GIR to the Swiss Federal Tax Administration, 15 months after the end of the reporting fiscal year (18 for the transitional year).
• If Switzerland receives a GIR from another jurisdiction, the Swiss constituent entity must notify the tax administration about the submission details, including the submitting entity and jurisdiction, with the same deadlines as mentioned above.
• The draft rules describe the organization, usage, and access of the GloBE information system, with data accessible through an electronic portal and destroyed within 20 years of receipt, as well as the content and format of the GIR.

The consultation closes on August 20, 2025, and the rules are scheduled to take effect on January 1, 2026.

Note that in Switzerland, the qualified domestic minimum top-up tax (QDMTT) became effective from January 1, 2024, and the IIR became effective from January 1, 2025.

Read a May 2025 report prepared by ÀÖÓ㣨Leyu£©ÌåÓý¹ÙÍø’s EU Tax Centre