KnowledgebasePillar Two Switzerland: the Global Minimum Tax
The OECD 15% global minimum tax in Switzerland: the QDMTT from 2024, the IIR from 2025, the GIR deadline, and why low cantonal rates no longer shield a group.
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Substance, Pillar Two & International Tax
Economic substance, the OECD global minimum tax and Pillar Two, and cross-border structuring — what a Swiss entity must do to withstand scrutiny.
Our Corporate Administration servicesEconomic substance is the real presence (people, premises and decisions taken in Switzerland) that lets a Swiss company keep its tax position, its treaty access and, since 2024, its standing under the OECD global minimum tax. Pillar Two sets a 15% minimum effective rate for groups with consolidated revenue of at least EUR 750 million. Switzerland brought in its domestic top-up tax (QDMTT) on 1 January 2024 and an income inclusion rule on 1 January 2025.
The combination changed the calculus. A low cantonal headline rate no longer shields a large group, because the shortfall to 15% is collected regardless; what survives the calculation is genuine activity, rewarded through the substance-based carve-out. The guides below explain what substance means in practice, how Pillar Two works in Switzerland, and what a special-purpose vehicle needs to be respected rather than looked through.
Economic Substance in Switzerland Explained
What economic substance means for a Swiss company: people, premises and board decisions taken here, who needs it, and what a defensible substance file holds.
ReadSwiss SPV Substance: Recognised or Disregarded
When a Swiss SPV is respected and when it is disregarded as a conduit: the resident board, office, books and beneficial ownership treaty access turns on.
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