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Switzerland is moving forward with the OECD/G20 Pillar Two
rules. Multinational enterprises with a Swiss nexus should prepare
for new compliance obligations. The first registration and filing
duties are approaching, and early action will be essential to avoid
penalties and ensure smooth processes with the tax
authorities.
Key take-aways are:
- Registration via OMTax has been open since early 2025 and is mandatory for DMTT purposes.
- First filings due by 30 June 2026 for fiscal year 2024.
- Two separate returns will be required: Local Information Return (LIR) and GloBE Information Return (GIR).
- Draft legislation foresees adoption of the MCAA for automatic exchange of GIR across jurisdictions.
- Swiss Constituent Entities can be designated to file the GIR for a multinational enterprise.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
