Switzerland publishes Guidance on the GloBE Information Return (GIR)

• Switzerland has published detailed guidance on the filing of the GloBE Information Return, marking the start of practical GIR compliance.
• The first Swiss GIR filing for FY24 is due by 30 June 2026, with filing relief dependent on the timely activation of exchange relationships.
• Given remaining uncertainties around exchange under the GIR MCAA, MNE Groups should prepare for potential Swiss local filing and focus on operational readiness.

Executive summary

The Swiss Federal Tax Administration (SFTA) has released guidance for filing the GloBE Information Return (GIR). This marks the practical start of the Swiss GIR filing process for FY24 due by 30 June 2026.

The GIR in the OECD Pillar Two framework

The GIR is a standardized information return that provides Pillar Two data for the entire MNE Group across all jurisdictions. Through the GIR, tax administrations obtain the data necessary to assess whether an MNE Group has correctly calculated its global effective tax rate and any resulting Top-up Taxes. It includes data points such as income, covered taxes, GloBE adjustments, and information on the Constituent Entities of the MNE Group. The GIR is informational only and is not a tax return. The actual determination and payment of Top-up Tax is made through separate Top-up Tax returns (QDMTT/IIR to be submitted via OMTax in Switzerland).

Who is required to file a Swiss GIR?

MNE Groups with consolidated revenue of >EUR 750 million in two of the four preceding fiscal years fall within the scope of the Swiss Minimum Tax Ordinance and are therefore required to file a GIR. By default, a GIR must be filed in Switzerland on an annual basis, meaning that the Swiss lead constituent entity is subject to a local filing obligation. This default requirement is waived if the GIR is filed by another Swiss constituent entity. Relief from Swiss filing also applies where the GIR is filed centrally by the Ultimate Parent Entity (UPE) or by a Designated Filing Entity (DFE) in another jurisdiction and a Multilateral Competent Authority Agreement (MCAA) is in place that enables the automatic exchange of the GIR between Switzerland and the respective jurisdiction. Switzerland has signed the GIR MCAA. It was approved by the Swiss Parliament in March 2026 and is expected to become legally effective in July 2026.

For a fiscal year ending on 31 December 2024, the GIR must be submitted to the SFTA by 30 June 2026 (18 months after the FYE) in XML format via the ePortal – the same platform used for submitting CbCR reports. For subsequent fiscal years, the GIR must be filed within 15 months after the end of the fiscal year.

Registration and GIR filing process in Switzerland

The SFTA has published guidance on how to register for and submit the GIR via the ePortal. The official GIR instructions are available online in German, French and Italian and can be accessed here: GloBE Information Return GIR.

The SFTA offers a test phase for GIR submissions in the ePortal test environment until 3 July 2026. During this period, MNE Groups can upload and validate GIR XML files. Entities can obtain the invitation code by sending a manual e-mail request including their “ESTV ID” as well as the date and time of registration. Test submissions are processed in the same way as actual filings, and the system issues a status message for each test file (accepted or rejected).

Exchange of GIR based on the MCAA

In Switzerland, the GIR MCAA will enter into force on 10 July 2026, provided no referendum is initiated, i.e., after the FY24 GIR filing deadline of 30 June 2026 but still before actual exchanges are expected to occur. The time needed for the ratification varies from jurisdiction to jurisdiction, with some jurisdictions not expected to have the agreement ratified in time for an exchange in 2026. At present, it cannot be conclusively determined whether, and in which circumstances, a GIR filed by 30 June 2026 will be exchanged. Under the GIR MCAA, the deadline for the exchange of GIR information is 31 December 2026 for the GIR related to FY24 (six months after the filing deadline; three months in subsequent years).

The OECD website provides a list of the activated exchange relationships that are currently in place for automatic exchanges under the GIR MCAA. As of 15 April 2026, 31 jurisdictions have signed the GIR MCAA. The OECD Secretariat is encouraging further signings of the GIR MCAA and the activation of a broad exchange network to enable central filing and facilitate first exchanges in December 2026.

Given the uncertainty around the timing and activation of exchange relationships under the GIR MCAA between Switzerland and other jurisdictions, exchange-based relief should be treated as a probable simplification, but not as an automatic right. MNE Groups should therefore, depending on whether exchange relationships are activated in time, prepare for the possibility that additional local GIR filings may be required in certain jurisdictions, including a Swiss GIR filing for groups filing outside of Switzerland.

Implications for MNE Groups

The publication of the GIR guidance by the SFTA marks a clear transition to active compliance under Switzerland’s Pillar Two regime. With the first Swiss GIR filing deadline of 30 June 2026 approaching, MNE Groups should now align their internal processes with the Swiss filing framework and ensure operational readiness.

In light of these developments, MNE Groups should focus in particular on the following actions:

• Complete ePortal registration and user access for relevant Swiss constituent entities.
• Test GIR XML generation and submission processes during the Swiss test window in order to identify technical or procedural issues ahead of the filing deadline.
• Monitor developments in the activation of GIR exchange relationships, while avoiding reliance on exchange-based relief alone for the first filing cycle.

The Swiss GIR filing process requires the Swiss constituent entity to be registered in the SFTA ePortal, with final activation dependent on an activation code sent by post to the registered Swiss address. Once the GIR service is activated, users and permissions must be set up. The GIR itself must be prepared externally in the OECD-prescribed XML format, as the ePortal does not generate GIR filings, and submitted via upload.