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An analysis by Tax Partner AG, Taxand Switzerland
The Organisation for Economic Co-operation and Development (OECD) has recently published Administrative Guidance clarifying the treatment of deferred tax assets (DTAs) under Art. 9.1 of the GloBE Model Rules. The guidance specifies how DTAs arising from post-30 November 2021 transactions, elections, or tax basis adjustments are excluded from GloBE income or simplified tax calculations.
René Matteotti and Patrick Bieri of our Swiss member firm Tax Partner AG highlight the key points of this guidance, including a grace period permitting up to 20% of harmful DTAs to be considered until 30 June 2027, except for transactions after 18 November 2024. Switzerland’s 2024 top-up tax qualifies for the QDMTT Safe Harbour if deferred tax effects are neutralised. Taxpayers are urged to review DTAs to ensure GloBE compliance, particularly during the first implementation year.
Read the full analysis and its implications for Swiss taxpayers here.
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