Switzerland: Tax Treaties

The OECD/G20 global minimum tax (Pillar 2) has fundamentally altered how tax-based business location incentives function for multinational enterprises. The January 2026 Administrative Guidance introduces the "Substance-based Tax Incentive Safe Harbour" framework, creating new opportunities through Qualified Tax Incentives (QTIs) that may preserve economic benefits of certain tax incentives under Pillar 2 rules, though with important limitations tied to substance requirements.

In a new landmark ruling 2C_506/2024 dated 4 May 2026 (intended for publication in the official collection), the Swiss Federal Supreme Court addressed for the first time the scope of attorney-client privilege where correspondence between a lawyer and a domestic tax authority is to be produced by that authority in response to a request made by a foreign state in international tax administrative assistance proceedings.

Switzerland's position as a leading global commodities trading hub is reinforced by competitive cantonal tax rates, efficient infrastructure, and a favourable regulatory environment.

Switzerland has long been a preferred destination for high-net-worth individuals (HNWIs) seeking financial stability, a high quality of life, and tax efficiency.

The US estate tax can have significant implications for non-US persons who own US securities or property within the United States.

The presentation of the Swiss Country Report on Subject no. 2 at this years IFA Annual Conference in Lisbon deals with treaty abuse from the source state's perspective.

If you are looking for a high quality of life in one of the world's most economically and politically stable countries, living in Switzerland could provide you with the ideal answer.

One particular aspect is without doubt "overlapping" taxation, which grants Germany unilateral taxation advantages.

Switzerland is an attractive jurisdiction for the location of a company for several reasons, as detailed in the Dixcart Swiss Company Jurisdiction Note.