Switzerland’s Federal Council has amended the Swiss Minimum Taxation Ordinance (OIMin) on 20 November 2024 due to the entry into force of the international supplementary tax Income Inclusion Rule (IIR).
The Federal Council decided on 4 September 2024 to implement the IIR from 1 January 2025, but it didn’t go through as the legislation had not yet been amended. For the IIR to enter into force in Switzerland on 1 January 2025, the OIMin must be amended accordingly.
This international supplementary tax (IIR) is in addition to the Swiss supplementary tax, which was introduced in 2024. Both taxes are intended to ensure that Switzerland retains the tax base resulting from the minimum tax of the Organisation for Economic Co-operation and Development (OECD) to foreign countries.
According to estimates, potential tax revenues for all government levels are expected to initially amount to between CHF 1.5 billion and CHF 3.5 billion. Foreign countries could recover the revenues if Switzerland decides not to implement the minimum tax.
The application of these rules also strengthens legal certainty and protects the companies concerned from additional tax procedures abroad.
