Top-up tax: Application of Section 2.6 of the administrative guidelines of December 18, 2023, concerning hybrid arbitrage arrangements within the temporary CbCR safe harbor
Berne, 12.08.2025 — The FTA announces the date of application of the rules on hybrid arbitrage arrangements within the temporary CbCR safe harbor of the administrative guidelines of December 18, 2023. The rules apply to transactions occurring after December 18, 2023.