INTERNATIONAL TAX PLAZA - The Federal Council adopted a dispatch regarding the exchange of information in the area of OECD minimum taxation

During its meeting of September 12, 2025 the Swiss Federal Council adopted a dispatch on approving the basis under international law for the exchange of information in relation to the OECD minimum tax rate. In the future, it should be possible for the multinational enterprise (MNE) groups concerned to submit this information centrally in 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 Swiss Federal Council brought the minimum tax rate of the OECD into force for domestic companies with effect from January 1, 2024. Moreover, in September 2024, the Federal Council decided to bring the income inclusion rule (IIR) into force with effect from January 1, 2025.

The relevant body of the OECD/G20 published the Multilateral Competent Authority Agreement (MCAA) 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 United Kingdom and France.

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.

According to a press release issued by the Swiss State Secretariat for International Finance ,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.

The provisional text of the dispatch concerning the approval of the Multilateral Competent Authority Agreement on the Exchange of Information Return for Global Anti-Base Erosion as adopted by the Swiss Federal Council as made available on the website of the Swiss Federal Department of Finance can be found here in the following languages (German, French and Italian);
The provisional text of the Federal Decree approving the Multilateral Competent Authority Agreement on the Exchange of Information Return for Global Anti-Base Erosion is available in the following languages (German, French and Italian);
The provisional text of the Multilateral Competent Authority Agreement on the Exchange of Global Anti-Base Erosion Information Return is available in the following languages (German, French and Italian); and
The report on the results of the consultation is available in the following languages (German, French and Italian).

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