精东影业

As of 1 January 2024, Switzerland, like other countries internationally, has decided to levy a supplementary federal tax, which is the measure defined in what is better known as OECD Pillar 2. This is basically a provision that allows multinational groups with an annual consolidated account of EUR 750 million to be subject to a 'minimum' rate of 15%. Switzerland chose to implement this measure by intervening with a constitutional amendment (Art. 129a and Art. 197, no. 15 Const.). On 18 June, the people and the cantons approved the federal decree empowering the Federal Council to implement the minimum rate by means of a temporary ordinance. The latter, called the 'Ordinance on Minimum Taxation' (OImM), will last for a maximum of six years, by which time the Federal Council will have to submit a replacement bill to Parliament. In line with the federal provisions, the Canton of Ticino has approved a legislative decree concerning the distribution among the communes (where the large companies involved are subject to tax) of the shares of the gross revenue from the supplementary tax due to the Canton. In the meantime, the minimum tax is being implemented in the form of a domestic supplementary tax, with which Switzerland is able to guarantee a 15% taxation for the target groups of companies at the domestic level, avoiding the outflow of the tax base from Switzerland to other countries, by means of the so-called 'Qualified Domestic Minimum Tax' (QDMTT). However, the 'Income Inclusion Rule' (IIR) and the 'Undertaxed Payment Rule' (UTPR), which would allow for the application of the supplementary tax internationally, remain suspended. In addition, a comparison will be made with what is happening in the canton of Graub眉nden, where at the beginning of the year the government gave the go-ahead for the consultation on the draft partial revision of the Tax Act and the Economic Development Act to implement the minimum tax rate.

Programme and speakers
The Federal Ordinance on Minimum Taxation of Large Corporate Groups
Peter R. Altenburger
Co-Founder and Counsel Altenburger Ltd. Legal + Tax

Sebastiano Garufi Giuliani
PhD, Lawyer, Adjunct Professor of Tax Law, L. Bocconi University, Milan Partner at Altenburger Ltd. Legal + tax

The Federal Ordinance on Minimum Taxation of Large Corporate Groups
Kathrin Egli Arginelli
Lawyer, LL.M. in International Taxation, Tax Expert dipl. fed., Deputy Director of the Taxation Division of the Canton of Ticino, Bellinzona

Quantification of the tax base and application of the so-called (Qualified) Domestic Minimum Tax (QDMTT)
Alessandro Turina
Senior Research Associate, International Bureau of Fiscal Documentation, Amsterdam; Adjunct Professor (International Tax Law), Bocconi University, Milan; Charg茅 de Cours (International Tax Law), University of Fribourg, Freiburg

The Implementation of the Minimum Tax Rate in the Canton of Graub眉nden
Angelo Roberto
Tax expert dipl. fed., Director, Cantonal Tax Administration Canton Grisons

Cost
CHF 350.
CHF 300 for members of partner institutions

Registration


Registration deadline
Friday 19 April 2024