Switzerland’s Federal Council has adopted an amendment to the Ordinance on the Minimum Taxation of Large Corporate Groups, under which OECD administrative guidance on deferred tax assets will apply only from financial years beginning on or after 1 January 2025. The change takes effect on 15 November 2026.
Switzerland’s Federal Council adopted the amendment at its meeting in Bern on 21 October 2026. It implements two parliamentary motions with identical wording, which called for the guidance to apply in Switzerland one year later than the date scheduled internationally.
What changes
The amended ordinance stipulates that the Organisation for Economic Co-operation and Development (OECD) administrative guidance will apply in Switzerland only to financial years beginning on or after 1 January 2025.
The guidance determines how deferred tax assets arising before the introduction of the minimum tax must be taken into account when calculating the effective tax rate. OECD member states adopted and published it in January 2025.
Internationally, the guidance is considered an essential document for interpreting the Model Rules. It therefore applies from the entry into force of the minimum tax, namely from 2024.
Parliamentary motions
By adopting motions 25.4392 and 25.4399, Parliament called for Switzerland to deviate from the OECD Model Rules on this one point. The amendment implements both motions.
Who is affected
The adjustment affects only a small number of corporate groups. In certain cases, it may result in a reduction in the domestic top-up tax payable in Switzerland for 2024, although the amount of the reduction cannot yet be quantified.
However, this reduction could be offset by the application of a foreign top-up tax. This could, for example, affect Swiss constituent entities of corporate groups whose ultimate parent entity is tax-resident in a European Union country.
Next steps
The amendment received broad support during the consultation process. It will enter into force on 15 November 2026, after which tax assessment procedures for the 2024 financial year can be concluded.
Background to the minimum tax
Switzerland introduced the OECD’s 15% minimum tax at the beginning of 2024. The Federal Council implemented it through the Ordinance on Minimum Taxation, based on the constitutional provision approved by the people and the cantons in 2023.
The regulations apply to multinational corporate groups with annual turnover of at least EUR 750 million. The ordinance ensures that the rules are applied in accordance with the OECD Model Rules. This prevents companies based in Switzerland from being exposed to a foreign minimum tax or increased legal uncertainty.
