Swiss Federal Tax Administration Issues Official Statements on Application of Pillar 2 Side-by-Side Package and Treatment of Deferred Tax Assets

The Swiss Federal Tax Administration (FTA) has issued Official Statements on 7 April 2026 concerning the application of the Pillar 2 Side-by-Side Package (Communication-031-E-2026-e of 07.04.2026), and the application of the administrative guidance on Article 9.1 of the Global Anti-Base Erosion Model Rules in relation to deferred tax assets (DTAs) arising from certain tax benefits, elections, choices or a newly introduced corporate income tax after 30 November 2021 (Communication-030-E-2026-…