Switzerland: Tax Treaties

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Article
Tax Incentives Under Pillar 2: New Opportunities Through Qualified Tax Incentives?
The OECD/G20 global minimum tax (Pillar 2) has fundamentally altered how tax-based business location incentives function for multinational enterprises. The January 2026 Administrative Guidance introduces the "Substance-based Tax Incentive Safe Harbour" framework, creating new opportunities through Qualified Tax Incentives (QTIs) that may preserve economic benefits of certain tax incentives under Pillar 2 rules, though with important limitations tied to substance requirements.
Switzerland Tax
LL
Loyens & Loeff
Article
Swiss Federal Supreme Court Limits Protection Of Attorney-Client Privilege In International Tax Assistance Proceedings
In a new landmark ruling 2C_506/2024 dated 4 May 2026 (intended for publication in the official collection), the Swiss Federal Supreme Court addressed for the first time the scope of attorney-client privilege where correspondence between a lawyer and a domestic tax authority is to be produced by that authority in response to a request made by a foreign state in international tax administrative assistance proceedings.
Switzerland Tax
BK
Bär & Karrer
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