Summary

The Federal Tax Administration (ESTV) provides information on the application of the administrative guideline to Article 9.1 of the GloBE Model Provisions dated January 13, 2025. This regulation affects the minimum taxation of large multinational corporate groups. The ESTV confirms that the administrative guideline and the grace period limitation contained therein apply under current law – until the Federal Council possibly amends the Minimum Taxation Ordinance (MindStV). The authority also specifies how the declaration for affected supplementary tax returns should be made.

Persons

  • Federal Tax Administration (ESTV) (Federal Authority)

Topics

  • Minimum taxation of multinational groups
  • GloBE Model Provisions (OECD)
  • Supplementary tax
  • Administrative guidelines
  • Declaration practice

Clarus Lead

The announcement addresses a central implementation question of the international minimum taxation reform: How are transition period extensions (grace period limitation) concretely applied in Swiss practice? The ESTV thereby creates legal certainty for affected companies and tax authorities during ongoing harmonization processes at the federal level.

Detailed Summary

The ESTV responds with this practice notice to two identically worded adopted motions that called for clarity on the application of the administrative guideline. The grace period limitation – a transition period restriction in the GloBE Model Provisions – is applied under Swiss law as long as the Federal Council does not decide on changes to the MindStV.

The regulation affects declaration practice: The ESTV establishes specific requirements for how supplementary tax returns for affected corporate groups must be structured. This practice notice serves to provide legal certainty and uniform application during international coordination of minimum taxation standards.

Key Statements

  • The ESTV clarifies the application of the administrative guideline to Article 9.1 of the GloBE Model Provisions
  • The grace period limitation applies under current law until a possible amendment to the MindStV by the Federal Council
  • The ESTV regulates declaration practice for affected supplementary tax returns

Critical Questions

  1. Evidence/Source Validity: What specific cases or scenarios led to the two identically worded motions, and how frequently do they affect Swiss corporate groups in practice?

  2. Conflicts of Interest: To what extent does the Swiss interpretation of the grace period limitation correspond to OECD standards, and are there deviations from other countries that could create competitive disadvantages?

  3. Causality/Alternatives: Why does the ESTV wait for a Federal Council decision on MindStV amendments instead of proactively adapting the guideline? What scenarios would lead to a change?

  4. Feasibility/Risks: How specific are the declaration requirements for affected companies? Is there a risk of interpretation discretion between cantons and the federal government?

  5. Data Quality: Are the impacts of this guideline on tax revenues and compliance costs for companies systematically recorded and later evaluated?

Source Directory

Primary Source: Supplementary Tax: Application of the administrative guideline to Article 9.1 of the GloBE Model Provisions – https://www.news.admin.ch/de/newnsb/l_dqw6_kuy6exJMZviEsb

Verification Status: ✓ April 7, 2026

This text was created with the support of an AI model. Editorial Responsibility: clarus.news | Fact-Check: April 7, 2026