BEPS 2.0: What impacts and new tax obligations for SMEs in Switzerland from 2025?

The international tax reform BEPS 2.0 is evolving rapidly and is disrupting the framework in which Swiss SMEs operate. While the subject initially concerned large multinationals, it is clear that compliance requirements and changes in practices are now increasingly affecting companies active in the local and regional economy—as early as 2025. What are the challenges for SMEs? What concrete obligations should they anticipate? What solutions should be implemented to remain confident in this new tax normality?

1. What is BEPS 2.0? Focus on a major evolution in international taxation

The BEPS initiative (Base Erosion and Profit Shifting) comes from the OECD and G20 to combat aggressive tax planning by international companies. The aim? To ensure that companies pay their fair share of taxes where they actually carry out their economic activities. After a first wave of measures (BEPS 1.0), BEPS 2.0 marks a new stage, notably through two pillars:

• Pillar 1: Partial reallocation of taxing rights towards market countries, even without significant physical presence.
• Pillar 2: Establishment of an effective minimum tax rate of 15% on profits of international groups with global turnover ≥ 750 million EUR.

1.1. Gradual extension to SMEs

Although immediate obligations only apply to large groups, the BEPS dynamic is already influencing tax audits and the heightened compliance expected by the Federal Administration. SMEs, particularly those with international connections or that are members of groups, are encouraged to update their practices to avoid increased risks of adjustments and penalties.

2. What will concretely change for Swiss SMEs from 2025?

Even if your company does not (yet) exceed the 750 million EUR threshold, several new obligations and practices are becoming widespread:

2.1. Strengthened documentation requirement

Transfer pricing documentation becomes a standard, including for smaller companies operating internationally. The administration expects to find supporting documentation at each audit (comparability studies, description of functions performed, scheme of financial/goods/services flows).

2.2. Expanded reporting and data reliability

Expectations regarding tax transparency lead to:

• Group reporting requirements (country-by-country reporting for certain groups)
• Increased attention to consistency between tax returns and financial reporting (Swiss GAAP FER / IFRS / Odoo)

2.3. Increased risk of double taxation

Tighter rules coupled with more effective international cooperation (AEOI, automatic exchange of information) make double taxation or disputes much more frequent. Anticipating these issues becomes crucial for cash flow and compliance.

2.4. Evolution of local audits

Cantonal administrations (e.g., Geneva, Vaud, or Zurich) are adapting their practices and can now rely on BEPS methodologies, even outside any formal BEPS obligation (see Administration fédérale des contributions – BEPS).

3. Best practices to anticipate and adapt (FAQ and concrete solutions)

3.1. Which audits or documents should be prepared today?

• Mapping all international transactions (goods, services, licenses, intra-group)
• Up-to-date transfer pricing file, including for SMEs not subject to mandatory reporting
• Fiscal and accounting harmonization (Swiss GAAP FER, Odoo)
• Checking consistency between financial and tax data, answers to authority questionnaires
• Effective tax simulations

3.2. How to prevent adjustments?

• Proactive review of intra-group contracts
• Drafting or updating the Master File and Local File (transfer pricing documentation), even in a simplified version
• Securing financial flows and adjusting ERP systems to guarantee traceability

3.3. Which tools or partners to prioritize?

• Accounting integration tools (e.g., Odoo adapted to the Swiss context)
• Support from a fiduciary experienced in BEPS anticipation issues for SMEs
• Regular knowledge updates, internal training adapted to the new requirements

3.4. How to manage Switzerland-specific risks?

Switzerland has chosen to integrate new international standards very early to remain competitive and credible. Dialogue with the Federal Tax Administration and anticipation of legislative changes are the best allies of SMEs (see OECD - BEPS actions).

4. Case study: Adaptation of a Geneva SME – BEPS 2.0 checklist

• Comprehensive mapping of flows (incoming/outgoing/group)
• Audit of existing documentation
• Training accounting staff to identify BEPS risks
• Configuring chart of accounts in line with international tax obligations
• Proactive dialogue with the fiduciary to anticipate any questions or audits

5. Conclusion: BEPS 2.0 as an opportunity for strengthening

The application of BEPS 2.0 to Swiss SMEs should be seen less as a constraint than as an opportunity to professionalize tax processes, limit the risk of sanctions, and promote company transparency. Support from a specialized partner equipped with suitable tools and continuous regulatory monitoring is the best asset for handling 2025 and beyond with peace of mind.

Would you like to anticipate the impact of BEPS 2.0 for your structure? Contact Ark Fiduciaire for a personalized tax planning audit.