OECD GloBE Rules (Pillar Two): What follows the first taxation decisions?

OECD GloBE Rules (Pillar Two): What follows the first taxation decisions?

With the filing deadline of the 2024 Swiss QDMTT return having ended on 30 June 2026, the first assessments from the relevant cantonal tax authorities will arrive in taxpayers' electronic mailboxes any time soon.

The GloBE Model Rules are extensive, complex and often subject to interpretation. Taxpayers may therefore wish to have disputed positions reviewed by a court in formal legal proceedings. The following summarizes the most relevant aspects of GloBE (Pillar Two) related proceedings in Switzerland.

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