Switzerland Ratifies Multinational Agreement on GIR Exchange

During its spring session, the Swiss Parliament ratified the multinational agreement on the exchange of information for global minimum taxation. Once the referendum period ends, Switzerland will be able to exchange and receive GloBE Information Returns from autumn 2026, with regard to the tax period 2024.

Switzerland has progressively implemented the global minimum tax through a constitutional amendment. Multinational groups and their subsidiaries operating in Switzerland are consequently subject to a domestic top-up tax (QDMTT) if they do not meet a minimum effective tax rate of 15%. An integral component of the global minimum tax framework is the information exchange regarding the calculation and application of the minimum tax, based on the standardised GloBE Information Return (“GIR”). The GIR enables tax administrations within their respective jurisdictions to validate local QDMTT and IIR tax returns.

Multilateral Agreement

The exchange of the GIR is governed by the multilateral competent authority agreement on the exchange of GloBE information (in German/French), developed by the OECD. Switzerland signed the agreement in summer 2025, however, national legislation requires ratification by the Swiss Parliament. Following Council of States' approval during the winter session, the National Council approved the multinational agreement in the spring session that concluded today.

From a procedural perspective, the consent of both chambers is subject to an optional referendum, which requires 50,000 signatures to be collected within 100 days. Such a referendum is highly improbable, given the agreement's non-contentious nature. The requisite amendments to the Minimum Taxation Ordinance have already been implemented with effect from 1 January 2026. Switzerland will therefore be able to exchange and receive the GIR for fiscal year 2024 from autumn 2026. Whether a Swiss multinational group will be exempt from filing the GIR outside of Switzerland will depend on the implementation status in the respective jurisdictions. Currently, only 28 jurisdictions have signed the agreement.

Deloitte’s View

With the ratification of the multinational agreement, Switzerland is now prepared for the first compliance cycle of the global minimum tax, which concludes on 30 June 2026. By this deadline, the QDMTT return must be submitted in Switzerland via the OMTax platform, and Swiss-headquartered groups must additionally submit the GIR. The GIR must be submitted via the separate ePortal operated by the Swiss Federal Tax Administration in XML format, which is also utilised for submissions such as Country-by-Country Reporting (CbCR). The respective GIR module will be made available shortly. Registration separate from the OMTax platform will be required. Importantly, the GIR can only be submitted in XML format. Further information on Swiss compliance requirements is available in an article by our Pillar Two specialist Manuel Angehrn (in German, behind a paywall). The expectation is that as many other jurisdictions as possible will ratify this agreement by summer 2026. Otherwise, affected groups in individual jurisdictions may be required to submit the GIR locally.