Other PE developments
Swiss Tax Authorities clarify domestic treatment of PEs under Pillar Two
On 18 March 2025, the Swiss Federal Tax Administration (FTA) released Communication-023-E-2025 , addressing the tax treatment of permanent establishments (PEs) under the Global Anti-Base Erosion (GloBE) rules and Switzerland's Minimum Taxation Ordinance.
The FTA clarified that, according to the GloBE rules, Swiss PEs of foreign entities are considered Constituent Entities of a Multinational Enterprise (MN…