This step provides the international legal basis for implementing the OECD minimum tax rate and will enable multinational enterprise groups to file the required information centrally through a single jurisdiction.
Switzerland’s Federal Council approved a dispatch establishing the legal framework for exchanging Pillar 2 GloBE returns under the Multilateral Competent Authority Agreement on the Exchange of GloBE Information (GIR MCAA) on 12 September 2025.
This step provides the international legal basis for implementing the OECD minimum tax rate and will enable multinational enterprise groups to file the required information centrally through a single jurisdiction.
On this basis, the jurisdictions participating in the exchange of information should be able to verify the plausibility of the tax calculations of MNE groups within the framework of the minimum tax rate. This proposal does not address national implementation.
In December 2023, the Federal Council brought the minimum tax rate of the OECD into force for domestic companies with effect from 1 January 2024. Moreover, in September 2024, the Federal Council decided to bring the income inclusion rule (IIR) into force with effect from 1 January 2025.
The relevant body of the OECD/G20 published the Multilateral Competent Authority Agreement on the Exchange of GloBE (Global Anti-Base Erosion) Information in January 2025. The GloBE agreement forms the basis under international law for the exchange of information between the implementing jurisdictions, which should have the requisite information to check whether the tax calculations of MNE groups are correct and in accordance with the GloBE rules.
The GloBE agreement is also intended to make it easier for the MNE groups concerned to fulfil their obligation to provide information in the context of the minimum tax rate. In the future, they will be able to submit the relevant information centrally in a single jurisdiction. The first exchange of information under the GloBE agreement is scheduled to take place in 2026. To date, just over a dozen jurisdictions aside from Switzerland have signed the GloBE agreement, including Japan, Italy, the UK and France.
During the consultation, which ran from January to May 2025, the proposal was well received by most participants.
The national implementation of this exchange of information on the minimum tax rate is the subject of a separate proposal, which was put out for consultation from April to August 2025.
The approval of the GloBE agreement and national implementation have no bearing on the possible future development of the OECD minimum tax rate. The Federal Council is closely monitoring international developments. As before, Switzerland is acting with the aim of creating legal certainty for companies based in Switzerland and securing the tax base in Switzerland.
Earlier, the Federal Council launched a public consultation on amendments to the Minimum Taxation Ordinance (MTO), introducing new reporting requirements for multinational companies under the OECD’s Pillar 2 rules on 30 April 2025.
