The Swiss Federal Tax Administration has issued Communication-023-E-2025-f of 18 March 2025 on its Communications page concerning the tax treatment of constituent entities that qualify as permanent establishments under the GloBE rules and the Swiss Minimum Tax Ordinance. The communication explains that while permanent establishments are considered distinct constituent entities for minimum tax purposes, according to Swiss law, they lack legal personality and the tax liability and procedural obligations fall upon the foreign parent entity, not the permanent establishment itself. Further, it is explained that the joint liability for the supplementary tax also applies to the foreign parent, with the...