OMTax: Pillar Two Federal Tax application launched in Switzerland

Cross-cantonal solution for the implementation of Pillar Two

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 750 million or more in at least two of the four prior fiscal years are subject to a QDMTT as from 1 January 2024 and an IIR as from 1 January 2025. Switzerland has not yet introduced an UTPR (for more information, see our our previous update.
• The first Swiss QDMTT or IIR return, as well as the first GloBE Information Return (GIR), are due within 18 months after the financial year-end, i.e., by 30 June 2026. However, information related to Pillar Two must be taken into account for the financial statements for 2024.

What is new for 2025?

• On 15 January 2025, the OECD released six 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.
• As noted above, OMTax was introduced in Switzerland on 2 January 2025 to enable companies to register and file their tax returns.

What do I need to do?

• Company contact details, information about the corporate group, authorizations and other information must be submitted through OMTax. After 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.
• A group will have to determine which group entity will be the designated filing entity in Switzerland for purposes of the registration and filing process. This entity is to be determined based on Switzerland’s Pillar Two Ordinance and is usually the top domestic business entity or the most economically significant business entity. The canton where the filing entity is located reviews the top-up tax declaration and is responsible for assessing and collecting the top-up tax.
• The designated entity must register in OMTax either directly or through a tax representative, and this must be completed before the tax return is filed, i.e. until 30 June 2026.
• Affected groups should begin to review and initiate the registration process now even though—unlike in other countries—there is no Pillar Two registration requirement before 30 June 2026. 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 handle this process for you as your tax representative.
• Please reach out to us for any questions or if you want us to provide further clarification on how your company is impacted by Pillar Two.