Other PE developmentsSwiss Tax Authorities clarify domestic treatment of PEs under Pillar TwoOn 18 March 2025, the Swiss Federal Tax Administration (FTA) released Communication-023-E-2025 , addressing the tax treatment of permanent establishments (PEs) under the Global Anti-Base Erosion (GloBE) rules and Switzerland's Minimum Taxation Ordinance.The FTA clarified that, according to the GloBE rules, Swiss PEs of foreign entities are considered Constituent Entities of a Multinational Enterprise (MNE) group and are subject to minimum taxation requirements in Switzerland (while domestic PEs of Swiss entities are not). However, under Swiss domestic law, a PE lacks legal personality and neither has legal capacity...