Top-up tax: application of the administrative guidance on Article 9.1 of the Global Anti-Base Erosion Model Rules adopted on 13 January 2025
Berne, 07.04.2026 — In the context of the minimum taxation of large multinational corporate groups, the FTA provides information on the application of the administrative guidance on Article 9.1 of the Global Anti-Base Erosion Model Rules adopted on 13 January 2025 in connection with two adopted motions of identical wording. The FTA clarifies that the administrative guidance and the Grace Period Limitation set out therein must be applied pursuant to applicable law and until the Federal Council decides on a possible amendment to the OMinT, and establishes how the declaration for the relevant top-up tax returns is to be made.