Reading Time: 3 Minutes
For Swiss businesses, 2025 was a year of structural upheaval with the activation of the OECD’s “Pillar Two” Income Inclusion Rule (IIR) and major VAT reforms. As we settle into 2026, the focus shifts from implementation to compliance and optimization.
Here is your executive summary of the critical tax developments affecting your bottom line this year.
1. Global Minimum Tax: The Compliance Cycle Begins
While the Domestic Top-Up Tax (QDMTT) has been active since 2024, the Income Inclusion Rule (IIR) officially came into force on January 1, 2025.
- The Status: Swiss-headquartered multinationals (revenues >EUR 750m) are now fully liable for the 15% minimum tax on their foreign low-taxed subsidiaries.
- The 2026 Action: This year is critical for reporting. The OMTax portal (launched Jan 2025) is now the mandatory channel for filing.
- Deadlines: Remember that the first QDMTT tax returns (for the 2024 business year) are typically due by June 30, 2026. Ensure your data points on “Substance-based Income Exclusion” (SBIE) are audit-ready.
2. VAT: The “Deemed Supplier” Reality Check
The platform taxation rules introduced in January 2025 have fundamentally changed Swiss e-commerce.
- The Shift: Online platforms (marketplaces) are now legally the “suppliers” for VAT purposes.
- The Business Impact: If you sell via platforms like Galaxus or Amazon, your VAT compliance burden has likely decreased, but your pricing strategy needs review. Ensure your margins aren’t being eroded by the platform’s VAT deduction handling.
- Audit Warning: The Federal Tax Administration (FTA) has signaled increased scrutiny on “mixed model” businesses (those selling both via platforms and their own webshops) to ensure correct revenue segregation.
3. Workforce & Payroll: Managing the “AHV 21” Shift
Payroll accounting in 2026 requires adjustments to match the phased “AHV 21” reforms.
- Retirement Age: As of January 1, 2026, the reference retirement age for women increases to 64 years and 6 months.
- 13th Pension Payment: The historic “13th AHV pension” payouts commence this year. While the payouts start now, the debate on funding (likely via future VAT hikes or wage deductions) remains a key political risk to monitor for your mid-term budget planning.
4. Cash Flow: Interest Rate Relief
There is a silver lining for corporate liquidity management.
- Federal Rates Reduced: Effective January 1, 2026, the default interest rate on late federal tax payments (including VAT and Direct Federal Tax) has been lowered to 4.0% (down from 4.5% in 2025).
- Opportunity: While paying on time is standard, the penalty for liquidity bridging has slightly softened.
5. What Didn’t Happen: No Tonnage Tax
For our clients in logistics and commodities:
- The Verdict: Following Parliament’s rejection in 2024, the proposed Swiss Tonnage Tax is officially off the table.
- Strategy: Shipping and trading firms should double-down on existing ordinary taxation optimization rather than waiting for a special regime that is no longer coming.
💡 Executive Next Step
Stress-test your “Pillar Two” Data Pipeline.
With the June 2026 filing deadline for the first QDMTT returns approaching, do not rely solely on your standard ERP outputs.
- Action: Conduct a “dry run” filing in the OMTax portal this month to identify data gaps before the deadline pressure mounts.