Executive Summary

The Swiss Federal Department of Finance opens a public consultation on 6 May 2026 regarding the amendment to the Minimum Taxation Ordinance (MindStV). The revision implements motions 25.4392 and 25.4399, which call for an adjustment to the application of the administrative guideline of the Inclusive Framework from January 2025. The guideline on Article 9.1 of the GloBE Model Rules shall apply only from fiscal years beginning on 1 January 2025 onwards. The consultation period ends on 14 July 2026.

Persons

  • Swiss Federal Department of Finance (lead)

Topics

  • Minimum taxation (international tax policy)
  • GloBE Model Rules (OECD standard)
  • Public consultation procedure (Swiss legislation)

Clarus Lead

Switzerland is clarifying its implementation of the international minimum taxation standard through a technical ordinance adjustment. The new regulation provides clarity on the temporal application of OECD guidelines and affects enterprises with global operations as well as cantons in tax harmonization.

Detailed Summary

The Minimum Taxation Ordinance is being amended to implement two parliamentary motions. These call for a precise regulation of the applicability of the administrative guideline of the Inclusive Framework from January 2025. The guideline refers to Article 9.1 of the GloBE Model Rules – an international framework for combating tax avoidance through minimum taxation. The amendment clarifies that this guideline applies only to fiscal years beginning on 1 January 2025 onwards, thereby creating legal certainty for affected enterprises and tax authorities.

The consultation invites interested parties (cantons, associations, business, academia) to submit comments. The period of over two months enables comprehensive consultation before final legislation.

Key Messages

  • Public consultation opening for the amendment to the Minimum Taxation Ordinance on 6 May 2026
  • Implementation of motions 25.4392 and 25.4399 with focus on the temporal application of OECD guidelines
  • Deadline for comments: 14 July 2026

Critical Questions

  1. Evidence: What concrete implementation problems or legal uncertainties has practice documented with the previous regulation?

  2. Conflicts of Interest: Which stakeholders benefit from the delay in the guideline's applicability to 2025, and which are disadvantaged?

  3. Causality: To what extent does the technical amendment to the ordinance fully address the substantive demands of the motions, or are further legislative steps planned?

  4. Feasibility: How will cantons and enterprises be informed about the new regulation, and how long is a transition period for compliance provided?

  5. Data Quality: Is the amendment based on an analysis of international implementation experiences with GloBE Model Rules in other countries?

Bibliography

Primary Source: Swiss Federal Department of Finance – Public Consultation Opening Minimum Taxation Ordinance – https://www.news.admin.ch/de/newnsb/eQKWxedRvMJPAVvmpCRcE

Verification Status: ✓ 6 May 2026

This text was created with the support of an AI model. Editorial responsibility: clarus.news | Fact-check: 6 May 2026