Multinationals can no longer treat the global minimum corporate tax as a distant reform. In 2025, OECD Pillar Two rules are being enforced across the EU, Switzerland, the UK, and other major economies. For groups with turnover above €750 million, the obligation is clear: maintain an effective tax rate of at least 15% in every jurisdiction, or face a top-up tax.
Swiss IP Migration: Managing Exit Tax Risk and Structuring a Defensible Transfer
This guide explains how to migrate intellectual property to Switzerland without triggering exit taxes. It covers valuation timing, substance requirements, transfer pricing discipline, and common structuring mistakes that attract audits. Learn how to design a defensible Swiss IP migration that withstands scrutiny from tax authorities, investors, and acquirers.