What happened?
The Swiss Federal Council adopted an amendment to its minimum-tax ordinance on 21 October 2026. It enters into force on 15 November.
Key details
The change defers Swiss application of the January 2025 OECD Article 9.1 deferred-tax guidance to fiscal years beginning on or after 1 January 2025. The government says only a small number of groups are affected; a lower Swiss domestic top-up tax for 2024 may be offset by foreign top-up tax.
Business impact
T&M analysis: begin with the origin and reversal of the relevant deferred-tax assets, rather than assuming all Swiss entities receive relief. Reconcile the Swiss calculation with the parent's jurisdiction and assess the applicable safe-harbour position. A lower domestic amount does not by itself establish a lower consolidated tax cost.
Preserve a bridge between financial-statement balances, the 2024 minimum-tax calculation and any foreign inclusion. Treat an expected saving as provisional until the cross-border calculation has been completed.
What happens next?
The Federal Council's release links the amendment and explanatory material. Its attached ordinance text is labelled provisional pending the authoritative official collection; use the definitive published text for implementation. News and analysis only; not tax, legal or investment advice.
Sources
Primary and secondary sources are distinguished below. See our methodology for verification and correction standards.