OECD Global Minimum Tax: GloBE Information Return – Filing Requirements and Deadlines for Swiss Groups
The OECD global minimum tax requires affected multinational enterprise groups not only to calculate and pay any applicable top-up tax but also to file a GloBE Information Return (GIR).
The introduction of electronic GIR filing in Switzerland creates additional requirements for group-wide data preparation, technical submission and coordination with foreign tax authorities.
Which Companies Are Required to File a GIR?
The reporting obligation generally applies to multinational enterprise groups with consolidated annual revenue of at least EUR 750 million, provided the relevant statutory conditions are met.
The GIR contains information on the group structure as well as income, taxes and calculations relevant to the OECD global minimum tax.
Swiss groups and Swiss constituent entities of foreign multinational groups must determine which entity is responsible for filing the return and whether Swiss reporting obligations can be fulfilled through centralised filing abroad.
What Are the Filing Deadlines?
The Swiss Federal Tax Administration (SFTA) provides for the following deadlines:
- Financial year 2024: For a financial year ending on 31 December 2024, the first GIR must be filed by 30 June 2026.
- Subsequent financial years: The GIR must generally be filed within 15 months after the end of the financial year.
- Financial year 2025: For a financial year ending on 31 December 2025, the filing deadline is generally 31 March 2027.
The applicable deadline must be determined based on the relevant financial year and transitional provisions.
How Is the GIR Filed Electronically?
The GIR must be submitted to the SFTA through the Swiss federal government’s ePortal.
The following requirements apply in particular:
- The return must be prepared in the prescribed XML format in accordance with the OECD schema.
- Submission by email, on paper or as an Excel file is not permitted.
- The SFTA does not provide its own conversion software for converting Excel files into XML format.
- The necessary access rights and registration must be arranged in advance.
- Incorrect returns must be corrected by submitting an amended GIR.
Technical preparation is therefore an essential part of meeting the filing requirements on time.
Can the GIR Be Filed Centrally for the Entire Group?
The international rules provide for centralised filing arrangements and the automatic exchange of information between the competent tax authorities.
Centralised filing can reduce the administrative burden, particularly for groups with numerous foreign constituent entities.
However, whether a separate filing in Switzerland is no longer required depends on the statutory conditions and applicable information exchange agreements.
The responsible group entity and the fulfilment of Swiss reporting obligations must therefore be carefully assessed.
Does the GIR Replace the Swiss Top-up Tax Return?
No. The GIR and the Swiss top-up tax return are two separate reporting instruments.
- GIR: Serves international reporting purposes and the exchange of information between tax authorities.
- Swiss top-up tax return: Is used to declare and assess the Swiss top-up tax.
Filing a GIR does not automatically exempt an entity from the obligation to submit a Swiss top-up tax return. Conversely, filing a Swiss top-up tax return does not replace the GIR.
The competent authorities and procedural requirements also differ.
What Are the Organisational Challenges?
For multinational enterprise groups, the following aspects are particularly relevant:
- Collecting the necessary financial and tax data from all affected constituent entities
- Reconciling the information with the consolidated financial statements and existing tax calculations
- Ensuring consistent application of the GloBE rules across the group
- Defining responsibilities for preparation, review and submission
- Technically validating the XML file before submission
- Monitoring filing deadlines and any necessary amended returns
Recommended Actions
Swiss groups and Swiss constituent entities of foreign multinational groups should review their GIR filing obligations at an early stage.
In particular, they should identify the group entity responsible for filing, assess whether centralised filing is available and prepare the technical submission process in good time.
For financial years ending on 31 December 2025, the next regular GIR filing deadline is generally 31 March 2027.
The official communications and statutory provisions issued by the Swiss federal authorities shall prevail.
Sources:
https://www.estv.admin.ch/de/globe-information-return-gir-de
https://www.estv.admin.ch/de/registrierung-gir