On September 12, 2025, the Swiss Federal Council approved the legal framework establishing the international legal basis for the exchange of information between jurisdictions in the context of the OECD’s global minimum tax. This measure will allow multinational groups to submit their tax calculations centrally in a single jurisdiction, enabling tax administrations to verify their correct application.
Although this decision does not yet imply the national implementation of the minimum tax, the Federal Council itself stressed that it represents a decisive step towards international cooperation on tax matters and a key advance in the global architecture of tax transparency.
This move reflects the growing pressure for more transparent and coordinated taxation. In an environment where intra-group financing structures and profit allocation policies have a direct impact on the tax base, timely access to reliable information becomes indispensable for tax authorities and for the prevention of cross-border disputes.
Scope of the measure
The new legal framework will allow Switzerland to exchange tax information with other jurisdictions to support the correct application of the global minimum tax. This mechanism not only seeks to reduce the administrative burden on multinational companies, but also to ensure that tax administrations have more robust tools for auditing.
In practical terms, the measure enables:
- Multinational companies to submit their minimum tax calculations in a single jurisdiction, avoiding duplicate reporting in each country where they operate.
- Foreign tax administrations to receive the relevant information to verify the results and, if necessary, question discrepancies.
- Mutual trust between jurisdictions to be strengthened by having a formal and structured channel for cooperation.
- Facilitate the detection of tax risks, especially with regard to financing structures, profit allocation, or transfer pricing policies.
However, this scheme does not replace local controls, but it does allow states to save resources by taking advantage of the centralization of information and reducing asymmetry in access to key data.
Fiscal transparency and transfer pricing
The introduction of a global minimum taxation standard cannot be separated from transfer pricing mechanisms. The calculations that will determine whether or not a group reaches the minimum tax threshold depend largely on how profits are distributed among related entities, the conditions agreed upon in internal financial transactions, and the correct valuation of intra-group transactions.
In this regard, the exchange of information takes on a strategic dimension: it will allow tax administrations to verify whether the policies applied by companies reflect market conditions, preventing profits from being artificially transferred to low-tax jurisdictions. For multinational groups, this means they must strengthen their comparability studies, justify the methods used, and document more rigorously every decision that affects the determination of taxable income.
Practical implications for multinationals
For companies, the immediate impact lies in the need to strengthen their tax compliance. It is not enough to correctly calculate the minimum tax burden; it will be essential to be able to demonstrate, to various jurisdictions, the consistency of internal policies that affect the final result. This ranges from the choice of comparables in financial transactions to consistency in profit allocation methods.
Filing reports in a single country can reduce administrative costs and offer some certainty. However, this requires ensuring the quality of the exchange between administrations. Nevertheless, it can also create risks if different states interpret the data received differently or if inconsistencies arise between local legislation and international standards.
Conclusion
The Federal Council’s decision to establish an international framework for the exchange of information on global minimum tax reinforces the trend towards more coordinated and transparent taxation. For multinational groups, the measure anticipates greater scrutiny of their internal structures and, in particular, of those policies that affect the allocation of profits and the setting of intra-group financial conditions.
Ultimately, the success of the minimum tax depends not only on its formal adoption, but also on the ability of states to share and use information effectively. In this new environment, the technical soundness of tax documentation-including that related to transfer pricing-will be the best shield against the risk of adjustments and penalties.
Source: Swiss Federal Administration