Swiss BEPS 2.0 Pillar Two implementation - applying IIR as per 1 January 2025, delaying UTPR indefinitely

On 4 September 2024, the Swiss Federal Council announced the application of the Income Inclusion Rule (IIR) effective from 1 January 2025. The application of the Undertaxed Profits Rule (UTPR) is delayed indefinitely.
Detailed overview
The legal basis for the Qualified Domestic Minimum Top-up Tax (QDMTT), IIR and UTPR has existed since the entry into force of the Swiss Pillar Two ordinance on 1 Janu…
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