The Swiss Federal Tax Administration has issued Communication-027-E-2025-e of 12 August 2025 - Top-up tax: application of Chapter 2.6 of the administrative guidance dated 18 December 2023. Chapter 2.6 of the OECD administrative guidance dated 18 December 2023 addresses the treatment of hybrid arbitrage arrangements within the context of the Transitional Country-by-Country Reporting (CbCR) Saf…