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International Tax Policy & OECD

International tax rules and treaties shape the framework conditions for companies operating across borders. For multinational companies, the effective implementation of international rules, the avoidance of double taxation, and strengthening Switzerland’s competitiveness as a business location are of central importance. SwissHoldings closely monitors developments in international tax policy and advocates for the interests of multinational companies at both the national and international levels.

Key Issues
09/17/2026

Double Taxation Agreements

Double taxation agreements allocate taxing rights between countries and help prevent the same income from being taxed more than once. For multinational companies, they provide legal certainty, facilitate cross-border investment, and reduce tax risks associated with international business activities. Switzerland has an extensive global network of double taxation agreements that is continuously expanded and modernized.

SwissHoldings' Position

  • A broad and reliable network of double taxation agreements (DTAs) is a key advantage for Switzerland as a business location. It helps prevent double taxation and provides predictable tax conditions for cross-border investment and business activities.
  • SwissHoldings supports the strategic expansion and continued modernization of Switzerland’s DTA network, particularly with emerging markets, where such agreements reduce investment risks and facilitate market access.

Topics: International Tax Policy and the OECD

09/17/2026

AEOI Agreement with the EU

The Agreement on the Automatic Exchange of Information (AEOI) governs the exchange of financial account information between Switzerland and the EU and is being adapted to reflect the latest international standards. For multinational companies in Switzerland, the withholding tax exemption for payments between related entities provided for under the Agreement is of particular importance.

SwissHoldings' Position

  • SwissHoldings supports the ratification of the amending protocol and, consequently, the continuation of the AEOI Agreement with the EU.
  • The withholding tax exemption under Article 9 is an important factor in Switzerland’s attractiveness as a business location for multinational companies with headquarters, research and development, intellectual property, and financing functions in Switzerland. It allows certain payments, such as dividends, interest, and royalties, between related entities in Switzerland and the EU to be made free of withholding tax, provided the applicable conditions are met, thereby avoiding additional tax costs.
  • Retaining Article 9 is essential: its removal would result in higher foreign withholding taxes and adversely affect both Switzerland’s attractiveness as a business location and its tax revenues.

Topics: International Tax Policy and the OECD

09/17/2026

OECD Minimum Taxation

The introduction of OECD minimum taxation fundamentally changed international tax competition. In early 2026, a major revision of OECD minimum taxation—the so-called “side-by-side” package—was adopted at the OECD level. The package primarily contains two key elements: First, the U.S. tax system was recognized as equivalent, thereby largely exempting U.S. companies from minimum taxation. Second, the package introduced administrative simplifications and a new option for substance-based tax credits for countries implementing OECD minimum taxation. For Switzerland, this creates new scope for OECD-compliant tax relief on labor costs and investment.

SwissHoldings' Position

  • SwissHoldings welcomes the administrative simplifications to the OECD minimum taxation rules and advocates for the most practical implementation possible of the international guidelines.
  • The new OECD-compliant, substance-based tax credits offer Switzerland the opportunity to provide targeted relief to companies that invest, create jobs, and generate genuine economic value.
  • The federal government and the cantons should make swift use of this new flexibility to strengthen Switzerland’s tax competitiveness and create attractive conditions for investment and high-value-added activities.

Topics: International Tax Policy and the OECD

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