Corporate Tax Newsletter Switzerland

Mutual agreement between Switzerland and Liechtenstein

On 17 April 2025, the State Secretariat for International Financial Matters (SIF) renewed a mutual agreement between Switzerland and Liechtenstein regarding the treatment of dormant estates for claiming treaty benefits. This updated agreement replaces the mutual agreement of 10 July 2015, and includes clarifications aimed at avoiding double taxation.
For more information, see the following link.

Mutual agreement between Switzerland and Sweden

On 22 May 2025, the State Secretariat for International Financial Matters (SIF) published a new mutual agreement between Switzerland and the Kingdom of Sweden regarding the avoidance of double taxation in the areas of income and wealth taxes. The agreement specifically addresses the application of procedural rules in Article 26 (Mutual Agreement Procedure), Paragraph 5, of the underlying treaty dated  7 May 1965.
For more information, see the following link.

Message on the expansion of the international automatic exchange of information on crypto assets

On 6 June 2025, the Federal Council adopted a proposal under which Switzerland shall automatically exchange information on crypto assets with 74 countries starting in 2026. The goal is to strengthen international tax transparency and prevent tax avoidance in the area of digital assets. The envisaged partner countries include all member states of the European Union, the United Kingdom, and the majority of the G20 countries. Excluded are, among others, the United States, China, and Saudi Arabia. However, the exchange of information will only take place if the countries concerned express an interest in exchanging information with Switzerland and meet the requirements of the Crypto-Asset Reporting Framework (CARF) developed by the OECD. Before the exchange begins, the Federal Council will examine whether the partner countries continue to meet the requirements of the standard. To this end, the existing review mechanism, which currently applies to the automatic exchange of information on financial accounts, will be extended to include crypto assets in the future. This requires corresponding adjustments to the current federal decree.
For more information, see the following link.

Pillar Two Country Tracker

Stay ahead of latest developments on Pillar Two implementation. Our Country Tracker provides the status of Pillar Two implementation in different countries and regions as well as a comprehensive summary of compliance and registration deadlines.
You can access the tool at the following link.

International Tax News

For ongoing updates from the international tax world, we recommend our international Tax News, which you can access at this link.

Consultation on the amendment of the Minimum Taxation Ordinance (MindStV)

On 30 April 2025, the Federal Council opened the consultation on the amendment of the Minimum Taxation Ordinance (MindStV). The aim of the amendment is to integrate the international reporting obligation according to the OECD Globe Rules (GloBE Information Return, GIR). This addition affects multinational corporate groups subject to the OECD minimum taxation and is intended to reduce their administrative burden.

The GIR reporting obligation is part of the international minimum taxation (Pillar 2) and requires affected corporate groups to submit a special tax return. This provides tax authorities worldwide with information on the group's income and taxes paid. In Switzerland, it enables the Swiss Federal Tax Administration (SFTA) and the cantons to verify the plausibility of the declarations of companies subject to supplementary tax.

The amendment to the ordinance specifically regulates the procedure for submitting the GIR to the SFTA. In addition, the international exchange of this information and its use by the cantons are stipulated. Switzerland relies on the one-stop-shop principle: Only one business unit per corporate group must submit the GIR to the SFTA. If the GIR is submitted by a partner country, a notification to the SFTA regarding the submitting business unit and its country of residence is sufficient.

The adjustment is in accordance with the international GloBE agreement, which regulates the multilateral exchange of information. The separate consultation process for the approval of this international legal basis is currently ongoing. Without participation in this exchange, corporate groups would have to submit the GIR multiple times in different countries, which would lead to duplication and increased administrative burden.

The full press release can be found at the following link.

Income and withholding tax: Determination of the maximum permissible conversion discount.

On 22 April 2025, the Swiss Federal Tax Administration published a notice on the tax treatment of the conversion discount for traditional convertible bonds and traditional convertible loans for income and withholding tax purposes. It explains the legal classification under Swiss law as well as the consequences for tax liability, procedural obligations, and liability consequences. The publication can be found at the following link.

Tax Information Dossier: “Withholding Tax”

The Swiss Federal Tax Administration published the dossier "Tax Information: Withholding Tax" on 19 June 2025. The content highlights various aspects of withholding tax related to foreign employees residing in Switzerland, cross-border commuters, and other categories of individuals. The dossier can be found at the following link.

Draft Amendment to the Withholding Tax Act (Too-big-to-fail Instruments)

On 6 June 2025, the Federal Council approved the message and the draft amendment to the Withholding Tax Act concerning too-big-to-fail instruments. The publication notice can be found at the following link.

Tax Information Dossier "Applicable Taxes"

The updated Tax Information Dossier "Applicable Taxes" was published on 26 May 2025. This dossier provides an overview of the various types of taxes levied at the federal, cantonal, and municipal levels. The publication can be found at the following link.

Publication of Withholding Tax Rates 2025

The  Swiss Federal Tax Administration has released the updated withholding tax rates for 2025, with corrections in the Canton of Vaud and updates across Switzerland for both salaries and other incomes. The publication can be found at the following link.

Tax statistics

The Swiss Federal Tax Administration published the "Tax Statistics 2024 – At a Glance" on 2 June 2025. The communication and the electronic version of the tax statistics can be found at the following link.

Corporate tax for radio and television

To ensure the financing of the constitutional mandate in the radio and television sector, the federal government levies both a household tax and a corporate tax. The Swiss Federal Tax Administration (SFTA) is responsible for collecting the corporate tax. In its capacity as the responsible collection agency, the SFTA published the activity report and the annual financial statements for 2024 on 28 May 2025. Link

Price lists (ICTax)

The Swiss Federal Tax Administration has updated the price lists and the bonus share lists for 2023 to 2025. The lists can be found at the following link.

Cantonal Gazettes

The Swiss Federal Tax Administration has published the cantonal gazettes for further cantons, which complement the topics covered in the Tax Information dossier and are linked to the tax folders. The cantonal gazettes can be found at the following link.

Tax policy proposals and initiatives

The Swiss Federal Tax Administration has updated the table overview of tax policy proposals and initiatives. The overviews can be found under the following link.

Canton of Zurich: Cantonal tax rate change rejected by cantonal voters

In the Canton of Zurich, a public vote on 18 May 2025, saw 54% of voters reject a proposal to further reduce the corporate income tax rate from 7% to 6%. This proposal followed an earlier tax rate reduction from 8% to 7% at the beginning of 2020. As a result, Zurich's combined effective tax rate (including federal, cantonal, and city of Zurich levels) remains unchanged (19.6% for 2025).

Companies should now reassess the actions they need to take to benefit from the following measures in the Zurich cantonal tax law if they have not already done so:

• Patent box with a relief of 90%.
• Additional deduction of 50% on R&D costs.
• Deduction on equity financing (Notional Interest Deduction).

These measures can significantly reduce the effective tax rate of a company in the Canton of Zurich, which can still be attractive under Pillar Two.

Canton of Zurich: Slight reduction in interest on taxes paid

The Executive Council of the Canton of Zurich has decided to adjust the reimbursement and balancing interest rates to align with the changing conditions in the interest rate environment. The new interest rates will come into effect on 1 January 2026. Due to developments in the interest rate environment, the reimbursement interest rate will be reduced from the previous 1.00 percent to a new rate of 0.75 percent. This reimbursement interest rate applies to early payments or overpayments made based on provisional invoices. To ensure consistent interest is applied to tax claims both before and after their due date, the Executive Council is also reducing the balancing interest rate to 0.75 percent. This rate applies to the period between the due date and the receipt of the final tax bill, as well as to differential amounts where the final assessment is higher than the provisional one. The default interest rate, which is charged if the final tax bill is not paid within 30 days, remains unchanged. The publication can be found at the following link.

Canton of Basel-Stadt: Ordinance on the Location Promotion Law published

On 18 May 2025, the Basel-Stadt voters approved the partial revision of the Location Promotion Package with 63% positive votes. The package includes changes in the Cantonal Location Promotion Law as well as in the Cantonal Tax Law. On 27 June 2025, the government council published the corresponding Ordinance on the Cantonal Location Promotion Law (Official Communication). The Ordinance came into force on 30 June 2025.

In addition, the Cantonal Council decided to set the changes of the tax law (2-rate approach and reduction of maximum relief) into force as per 1 January 2026.

Now, here are the key features of the Ordinance on the Basel-Stadt Location Promotion Law:

The funding areas Innovation and Environment are available for all corporations and cooperatives subject to unlimited taxation in Basel-Stadt or subject to limited taxation with at least one qualifying asset in the canton (i.e. depreciation on tangible assets for R&D or on high-tech production of at least 100’000 CHF during the fiscal year). The financial support for voluntary parental leave is however available for all legal entities and branches/permanent establishments in the Canton of Basel-Stadt.

The grants are made in the form of grants, qualified tax credits or other recognized tax credits and are awarded once a year upon application. The amount of the grants is based on documented expenditures or avoided greenhouse gas emissions.

Grants for the area of innovation require a regular statutory audit of the company and confirmation of the grant application by an auditor.

As a special note we would like to highlight that the support of clinical trials is limited to Swiss clinical trial costs, only.

The application requests for the relevant business year 2024 must be submitted for all funding areas by 30 September 2025, via an electronic platform. This platform is expected to be available from mid-August 2025 on ePortal. To prevent overbooking of the funds, the government council may set a reduction rate, applicable to all support except for parental leave and contributions to research cooperation. The first disbursements are expected to occur in spring 2026.

Canton of Obwalden: Tax Law Amendments

On 26 June 2025, the government council of the Canton of Obwalden decided on amendments to the tax law, including, among other things, the elimination of tax inequalities with the minimum tax on properties, from which real estate companies will now also benefit, as well as the introduction of uniform deadlines for objections. In addition to these, there are further changes that will also take effect on 1 January 2026. These measures aim to create more clarity and fairness for businesses. More information here.

Canton of Schaffhausen: Tax Law Amendments

The Canton of Schaffhausen has announced on 4 June 2025 amendments to its tax legislation. These changes address Federal Court decisions, requiring the canton to incorporate adjustments from the federal tax framework into its laws, impacting corporate tax compliance. The tax changes address home office in international contexts, collective investments with real estate, and publicly-owned companies. Updates include data sharing regulations and tax notice delivery abroad, along with a correction in the wealth tax rate. The revision improves legal certainty with minimal financial impact, negating the need for a consultation process. For additional details, please refer to the publication on the official canton website under the following link.

Current case law

Enclosed you will find a selection of the Swiss Federal Court (SFC) and Swiss Federal Administrative Court (SFAC), that may be of interest to you:

• SFC dated 2 April 2025: The Federal Supreme Court ruled on which canton is entitled to tax the income from the reversal of the replacement provision.
• SFC dated 4 April 2025: The Federal Supreme Court ruled on the direct federal taxes and cantonal and communal taxes for 2022 (Zug). Articles 133 and 140 of the Swiss Federal Tax Law govern the time limits for direct federal tax exclusively and do not provide for a halt in deadlines over Christmas and New Year. The Canton of Zug also does not stipulate a suspension of deadlines for tax proceedings during this period. Given that the decision on the objection was delivered on 7 December 2024, via P.O. Box (A-Post Plus), the appeal filed on 8 January 2025, was late, and the lower court correctly dismissed it.
• SFC dated 8 April 2025: The Federal Supreme Court stated that the managing director's residence cannot be used as a secondary tax domicile if it is unclear where the company's decisions are primarily made. If, considering all circumstances, it cannot be determined with the required level of proof that decisions are mainly made elsewhere, unlimited tax liability outside the registered canton is excluded.
• SFC dated 22 May 2025: In its decision, the Federal Supreme Court addressed, among other things, whether the taxpayer met the conditions for the reinstatement of missed deadlines in the objection procedure.
• SFC dated 24 April 2025: The Federal Supreme Court ruled that the tax assessment of a provision for WEKO fines, along with the subsequent denial of its deductibility, can be made at the time of its reversal, even if it was considered tax-deductible when initially established in the previous year.
• SFC dated 29 April 2025: The case concerned whether the unlimited tax liability of the holding company was in the Canton of Obwalden, where its registered office was located, or in the Canton of Zurich. The Federal Supreme Court fully sided with the appellant, as not all board members resided in Zurich, and the lower court failed to establish the actual management in a specific location within Zurich. The fact that the majority of board members lived in Zurich was insufficient to assume that the actual management was there.
• SFC dated 21 May 2025: The Federal Supreme Court ruled, that the prohibition of double taxation under Art. 127 para. 3 of the Swiss Constitution is not a reason for revision. The appeal process must be completed in the canton responsible for the final assessment. The tax representative should have known the deadline rules for weekend delivery of A-Post-Plus mail. The missed deadline should have led to a timely request for deadline reinstatement, not a revision request a year later.

PwC newsletter

We hope that this newsletter contains some topics of interest to you. If you have any questions, please do not hesitate to contact us. For ongoing updates from the world of tax, we also recommend our personalized newsletter, for which you can register using the following link.

Switzerland in focus

Getting people paid on time and accurat isn’t just good practice, it’s essential. Yet as rules multiply and shift, businesses worldwide face an uphill battle to stay compliant. In June 2025, PwC published its Global Payroll Complexity Index, assessing over 50 countries across seven dimensions, from statutory filings to data protection, to produce an overall complexity score for each jurisdiction. 

Read more here.

VAT

Switzerland – New digital transfer procedure declaration

Swiss VAT-registered businesses using the transfer procedure (= Verlagerungsverfahren; importer does not pay the import VAT owed at the import to the FOCBS but declares in VAT return) must now declare import VAT digitally via the FTA ePortal. The separate submission of paper forms is no longer required.

This update streamlines and simplifies the import tax declaration process, reducing administrative burden and aligning with Switzerland's broader digitalization efforts.

Recommendation: We recommend preparing for the changed declaration process.

Customs

New progress related to EFTA Free Trade Agreement with India

After over 15 years the EFTA Member States, and India reached an agreement which was signed in March 2024. Now the Swiss parliament gave a green light for this agreement. The subsequent referendum deadline also passed in mid-July without any referendum being initiated. The agreement covers trade in goods and services, investment promotion, intellectual property, government procurement, competition and sustainable development. It commits EFTA states to maintain duty-free access for Indian industrial products, while India reciprocates with significant tariff reductions for EFTA exports. The agreement features detailed rules of origin, trade facilitation measures, and sector-specific commitments in services, as well as innovative provisions for investment promotion and cooperation. It also includes comprehensive intellectual property protections, mechanisms for addressing anti-competitive practices, and a strong focus on sustainable development, gender equality, and labour standards. Oversight is provided by a Joint Committee, with a structured dispute settlement process to ensure effective implementation and resolution conflicts.

Swiss Customs Act accepted by the Parliament

On Friday, 20 June 2025, a significant milestone was reached as the revised Customs Law was approved by Parliament, paving the way for a major transformation of the Swiss customs framework. Now this legal act will become subject to the referendum (the deadline for the referendum will be set in the coming weeks). The foreseen entrance into force date is 2027/2028. The reform will contain simplification of all processes for the collection of duties and the control of cross-border movement of goods and people by the BAZG, establishment of a uniform, fully digital procedure and promotion of the most automated possible review of non-duty-related regulations. Furthermore, it contains adaptation of duty-related and non-duty-related regulations that are associated with the Customs Duties Act. If you would like to read more in detail about the changes in Swiss Customs law, please check out our latest blog post.

VAT

Italy – uses AI to tackle VAT Fraud – Is Your Master Data Prepared?

• The Italian tax authority, in partnership with Sogei and the Ministry of Finance, has introduced an AI-powered chatbot that works alongside the existing VeRa algorithm to check VAT returns.
• This chatbot actively analysis VAT filings in real time, identifying anomalies (e.g., mismatched invoices, undeclared income).
• Alerts are shared instantly with tax officers to priorities high-risk cases and accelerate enforcement.
• In 2022, over 1 million suspect filings were detected through AI. In parallel, targeted VAT adjustments will apply.

Recommendation: We recommend that companies proactively clean and standardize their tax data to reduce compliance risks and prepare for AI-driven tax enforcement.

Portugal – Updated VAT compliance procedures

As of July 2025, Portugal is streamlining its VAT compliance procedures with new guidance. This should ease filing obligations and clarify key thresholds for businesses.

Key Changes:

• Taxpayers can opt into monthly filing without being bound for a minimum of 3 years (previously required).
• Frequency changes (monthly ↔ quarterly) must be requested by filing an amendment in January, effective from 1 January.
• Taxpayers with turnover ≥ EUR 650’000 in the previous year must file VAT returns monthly, starting January 2026.
• Turnover calculation for periodicity excludes certain operations and is based on normal business activities.
• Restrictions remain for taxpayers benefiting from monthly VAT refund or import VAT payment via periodic returns (must be done electronically on the tax portal with specific deadlines).
• Changes in filing frequency are no longer made by the Tax Authority automatically, except in cases of non-compliance.

Recommendation: We recommend reviewing your 2025 turnover projections to determine your applicable VAT return frequency in 2026 and planning the required system and reporting adjustments accordingly.

European Union – New VAT approach for distance sales of imported goods and import VAT

Key Update:

• The Council has agreed on a directive to improve the collection of VAT on imported goods by making the supplier liable for the VAT paid on imports, encouraging use of the VAT Import One-Stop Shop (IOSS) regime.
• IOSS allows foreign traders or platforms to register in a single member state to simplify VAT declaration and payment for sales made throughout the EU.
• By requiring upfront VAT payments at the point of purchase, it shifts the burden of VAT collection from consumers to platforms and protects member states' tax revenues.
• The update streamlines VAT compliance for online sellers and enhances VAT collection efficiency.
• Non-IOSS users may face fallback mechanisms (e.g., VAT payable by the customer before delivery).

Recommendation: We recommend checking whether IOSS regime should be used in your case. 

Customs

Changes in the US Trade and Tariff Policy

Recent developments in the US trade policy under President Trump have led to significant changes, particularly in the area of tariffs and trade regulations. In April, a series of announcements and new regulations marked a period of escalating trade tensions between the US and China. President Trump imposed multiple rounds of tariffs on Chinese goods, with rates ultimately reaching a peak of 145%. In response, China implemented its own tariffs on US imports, peaking at 125%. During this period, the US also ended the de minimis exemption for low-value imports from China and Hong Kong, making all such packages subject to tariffs. At the same time, China introduced new export licensing requirements for seven types of rare earth elements, further tightening its control over these critical materials.

Amid these escalations, both countries entered negotiations and reached a temporary agreement in Geneva. This agreement reduced tariffs to 30% for the US and 10% for China and included a 90-day pause on the introduction of additional trade barriers.

The Trump administration also targeted specific products with tariffs: as of 3 April 2025, a 25% ad valorem tariff was imposed on automobiles, followed by a 25% ad valorem tariff on automobile parts as of 3 May 2025. Furthermore, on 4 June 2025, tariffs on steel and aluminium were increased from 25% to 50%.

After many complaints submitted into the various US Courts, in June 2025 the US Court of International Trade intervened, ruling that some of the tariffs imposed by the Trump administration exceeded presidential authority. The administration appeal to this decision resulted in an administrative stay on the reciprocal and fentanyl tariffs until the court proceedings conclude.

In addition to the above developments, the United Kingdom became the second country to reach a trade agreement with the US. Announced in mid-June 2025, the agreement established an annual tariff-rate quota allowing up to 100,000 UK-made automobiles to be imported into the US at a reduced combined tariff rate of 10%. UK automobile parts intended for use in these vehicles are also eligible for the reduced 10% tariff instead of the standard 25%. The agreement further provides for the establishment of similar tariff-rate quota schemes for UK steel and aluminium imports, as well as preferential treatment for UK pharmaceuticals and pharmaceutical ingredients.

The third country that reached a deal with the White House is Vietnam, which will be subject to 20% ad valorem tariffs instead of 46% that were announced on 2 April 2025.

Furthermore, on 7 July 2025 it was announced that the suspension of the country specific reciprocal tariffs was extended until 1 August 2025. Furthermore, it was also announced that the US president starts to send letters to the heads of following states to inform them about new tariffs rates. Based on this announcement as of 1 August 2025 goods originating from Japan will be subject to 25%, Bangladesh - 35%, Bosnia and Herzegovina – 30%, Cambodia – 36%, Indonesia -32%, Kazakhstan - 25%, Laos – 40%, Malaysia – 25%, Myanmar – 40%, Serbia – 35%, South Africa – 30%, South Korea – 25%, Thailand – 36% and Tunisia – 25%. The US administration also reserve themselves the right to send revision reciprocal tariff letter to other countries.

EU adopted 17^th package of sanctions against Russia

The 17^th package of EU sanctions against Russia introduces the most extensive measures to date, primarily targeting Russia’s shadow fleet of oil tankers and expanding restrictions on technologies and entities supporting the Russian war effort. The package lists 189 additional vessels involved in transporting Russian oil, bringing the total to 342, and subject them to port access and services bans, making it significantly harder and costlier for Russia to export oil and evade the price cap. It also adds 31 new companies – both Russian and from third countries – to the sanctions list for supporting Russia’s military – industrial complex or engaging in sanctions circumvention and expands export restrictions on dual-use and advanced technology items, such as chemical precursors for missile propellants and spare parts for high-precision machine tools.

Additionally, the package includes 75 new listings of individuals and entities, mainly from the Russian military and defence sectors, who are now subject to asset freezes, travel bans, and prohibitions on making economic resources available to them. These measures are complemented by new criteria targeting shadow fleet enablers and actors involved in the looting of cultural heritage or activities in occupied territories. The package also extends the exemption from the oil price cap for crude oil transported from Russia’s Sakhalin-2 project to Japan, ensuring Japan’s energy security until 2026. Overall, these provisions aim to further restrict Russia’s access to critical resources and revenue, increasing economic pressure and complicating its ability to sustain its war against Ukraine.

EU customs reform – Council reached an agreement

The EU is undertaking a fundamental reform of its customs framework to modernize and strengthen the way customs authorities manage increasing trade volumes, especially in e-commerce, and to better enforce EU standards at the border. Key elements of the reform include the creation of a new decentralised EU customs authority to coordinate risk management and crisis response, and the establishment of a single EU customs data hub, which will be an online platform where businesses can submit customs information once for all consignments. The reform also introduces enhanced customs simplifications for the most trusted traders, a new category called “trust and check traders” and maintains the existing authorised economic operator (AEO) scheme to support SMEs. Additionally, a handling fee will be introduced for small consignments entering the EU through distance selling.

With the Council’s agreement on a partial negotiating mandate, interinstitutional negotiations with the European Parliament will now begin on the core aspects of the reform. Some issues, such as the location of the new EU customs authority, the design of a simplified tariff system, and the specifics of the handling fee, will be addressed in later discussions. The overall aim is to provide customs authorities with more effective tools to protect the Single Market, ensure efficient collection of duties, and facilitate legitimate trade without imposing unnecessary burdens on businesses or authorities.   

ECJ Tauritus case – provisional prices

The European Court of Justice’s judgment, which was released on 15 May 2025, in Tauritus UAB case clarifies that importers can use the transaction value method for customs valuation even when the final price of imported goods is unknown at the time of importation, provided the final price is later determined based on objective, contractually agreed factors such as market prices or exchange rates. In such cases, importers should initially declare a provisional value using a simplified customs declaration and submit a supplementary declaration once the final price is established. The Court distinguished this scenario from the Hamamatsu case, emphasizing that only prices determined by objective, pre-agreed criteria-not unilateral adjustments- are suitable for this approach. The judgment highlights the importance of transparent, contractually defined pricing mechanisms and strict adherence to customs procedures, as customs authorities may scrutinize provisional or transfer pricing arrangements more closely. If you would like to read more about decision of the court and its implications for businesses, please check our blog post.

Environment – Social – Government

Environment – Social – Government («ESG») levies

In the EU, we are currently facing significant updates in the ESG (Environmental, Social and Governance) tax landscape. In terms of packaging, the EU published in January 2025 the new Regulation of Packaging and Packaging Waste (PPWR) in order to reduce packaging waste, promote reuse and recycling, and enhance resource efficiency. It aims to create a circular economy by reducing dependency on primary resources and encouraging sustainable packaging solutions.  The regulation will be fully operational in August 2026 and include among others, restrictions on hazardous substances in packaging (per- and polyfluorinated alkyl substances or PFASs) to protect consumer health and the environment, implementation of Extended Producer Responsibility (EPRs).  The Regulation focuses on packaging waste reduction by encouraging reusable and refillable packaging solutions. In terms of requirements, based on the new regulations, all packaging placed on the EU market should be designed for recycling by 2030 and recycled at scale by 2035 according to recycling performance grades (A (95%), B (80%), C (70%) & Non-Recyclable) and recycled at the scale score. Companies will be required to optimize the packaging flow as well as to redesign their packaging and comply with the new requirements.

In terms of Carbon Border Adjustment Mechanism (based on the latest updates due to the Omnibus proposal) a de minimis threshold of 50 tonnes mass and simplifying compliance for small importers which are below the threshold are noted. Importers who are in scope of CBAM will need to apply for authorized CBAM declarant status to continue importing CBAM goods from 1 January 2026. The application process for authorized CBAM declarants began in March 2025. 

The European Union Carbon Border Adjustment Mechanism (CBAM)

After two years of transitional period, the CBAM definitive period will start on 1 January 2026. Less than six months before, the European Commission, the European Council, and the European Parliament are still in the process of finalising important details as part of the Omnibus package

These details under review relate to a de minimis exemption as well as the authorisation procedure, the data collection processes, the calculation of embedded emissions, the emission verification rules, the calculation of the CBAM declarants’ financial liability during the year of imports, and the claim by CBAM declarants for carbon prices paid in third countries where goods are produced.

What is clear at this point is that:

1. Companies need to apply for the status of authorised CBAM declarant by the end of 2025 to be able to import CBAM goods from 1 January 2026.
2. Companies will need to collect the required trade and emissions data in 2026 to be able to file their CBAM declaration in 2027.
3. In 2027 companies will need to buy CBAM certificates to offset their 2026 imports (backward-looking) as well as their ongoing imports (forward-looking).

Please do reach out to us to discuss these topics and in particular the establishment of governance processes, technology-enabled data collection procedures, and the creation of a strategic financial plan for 2026.

The European Union Deforestation Regulation (EUDR)

On 15 April 2025, the European Commission released updated guidance, FAQ documents, and a draft Delegated Act addressing open questions and clarifications regarding the EUDR. Through these simplifications, the Commission anticipates a 30% reduction in administrative requirements for businesses before the EUDR applies to large operators and traders on 30 December 2025, and to SMEs by mid-2026.

This move is aligned with the EU’s broader harmonization and simplification strategy. The updates cover exemptions and product scope for certain commodities, clarify downstream operators’ obligations, and offer detailed guidance on Due Diligence Statement (DDS) submissions.

Key points of the updates include:

• Clarification that the definition of SME under EUDR is based on entity level rather than on group level.
• Re-imported products can reuse prior DDS during the transition period, and a single DDS can cover multiple shipments with an annual submission required.
• Non-SME companies must collect and verify suppliers' DDS reference numbers as additional steps to ascertain that relevant products have been subject to proper due diligence.
• Exemptions from EUDR obligations apply to items of correspondence, second-hand products intended for waste, specific packaging materials, and product samples used exclusively for testing purposes.

The European Commission has also released the country benchmarking list under the EUDR on 22 May 2025. This list classifies countries into low, standard, and high-risk categories, which aims to streamline due diligence processes for operators importing these EUDR commodities into the EU. On 9 July 2025, the EU Parliament has rejected the country benchmarking, consequently, the EU Commission needs to re-work the classification.

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Does your pharma company sell products to EU wholesalers? Recent regulatory changes in the EU are reshaping the landscape for Swiss pharmaceutical companies. These changes could significantly impact your operations and supply chain. Learn more about the challenges and potential solutions in our latest blog post. 

In June 2025, the Swiss Federal Tax Administration (SFTA) has updated its transfer pricing website page structured in the form of a Q&A. The website builds on previous guidance and provides further clarification on withholding tax (WHT) in connection with primary, corresponding and secondary adjustments.

This update is particularly relevant in light of increasing scrutiny by the SFTA on intra-group transactions and a growing number of cases involving Mutual Agreement Procedures (MAPs). With no dedicated Swiss legislation on transfer pricing, these Q&As continue to be a key source for understanding how transfer pricing related matters are applied by the SFTA in practice.