The comment of the AFBS focuses on two key points which are of concern to the foreign banks in Switzerland:
1. The AFBS suggests the top-up tax and the intercantonal distribution of the tax revenue to be carried out based on known mechanisms.
2. The AFBS agrees with the Federal Council that the OECD Minimum Tax should enter into force on 1 January 2024 and there should not be a retroactive application of the measures. 
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