Get Ready for Pillar TWO –
Registration and Filing with Swiss Tax
Authorities

Switzerland is moving forward with the OECD/G20 Pillar Two rules. Multinational enterprises with a Swiss nexus should prepare for new compliance obligations. The first registration and filing duties are approaching, and early action will be essential to avoid penalties and ensure smooth processes with the tax authorities.

Key take-aways are:

• Registration via OMTax has been open since early 2025 and is mandatory for DMTT purposes.

• First filings due by 30 June 2026 for fiscal year 2024.
• Two separate returns will be required: Local Information Return (LIR) and GloBE Information Return (GIR).
• Draft legislation foresees adoption of the MCAA for automatic exchange of GIR across jurisdictions.
• Swiss Constituent Entities can be designated to file the GIR for a multinational enterprise.