OMTax: Pillar Two Federal Tax application launched in Switzerland

Cross-cantonal solution for the implementation of Pillar 2

What should I already know?

• Swiss entities (including foundations and trusts) that are part of a multinational enterprise ("MNE Group") that has annual revenue of EUR 750m or more in at least two of the four prior fiscal years are subject to the QDMTT from January 1, 2024, and IRR from January 1, 2025. Switzerland has not introduced a UTPR for the time being. More information can be found in our previous update.
• The first Swiss QDMTT or IRR return as well as the first GloBE Information Return (GIR) are due within 18 months after the financial year end i.e. June 30, 2026. However, information related to Pillar 2 already needs be considered for the financial statements for 2024.

What is this year's news so far?

• On January 15, 2025, the OECD has released 6 additional publications and more than 300 pages of guidance related to the GIR and three Administrative Guidance documents that we will address separately in an update.
• OMTax was introduced in Switzerland on January 2, 2025 to enable companies to register and file their tax returns.

What do I need to do?

• Company contact details, information to the corporate group, authorizations and other information have to be submitted through OMTax. After the registration is submitted, it will be checked by the responsible canton and the company will receive a letter with the activation code at the registered address of the taxable constituent entity.
• In particular, a company needs to determine which is the designated filing entity in Switzerland for the registration process. This entity is determined as per the Swiss Pillar 2 ordinance and is usually the highest domestic business entity or the most significant business entity. The canton where this filing entity is located reviews the top-up tax declaration and is responsible to assess and collect the top-up tax.
• We recommended to review and start the registration process already now even though there is no Pillar 2 registration requirement before June 30, 2025, unlike in other countries. This process is also mandatory for Groups that will apply the transitional CbCR safe harbour.

BDO can support you.

• BDO can support you during the registration process and can also handle this process for you as your tax representative.
• Please reach out to us for any questions in this matter or if you want us to provide further clarification how your company is impacted by Pillar 2. Therefore, various guidance's published by the OECD and by the Swiss tax authorities need to be reviewed and followed.