The Swiss Federal Tax Administration has issued Communication-026-E-2025-e of 24 July 2025 - Top-up tax: consideration of residual tax on distributions from qualifying participations from 1 January 2024.
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Top-up tax: consideration of residual tax on distributions from qualifying participations from 1 January 2024
1. Background
The top-up tax (supplementary tax) is calculated based on the provisions of the Global Anti-Base Erosion Model Rules of the Inclusive Framework on BEPS of the…