Country-by-country reports
With the exchange of country-by-country reports is Switzerland implementing a minimum standard of the G20 countries and the OECD to combat base erosion and profit shifting (BEPS).
On 1 December 2017, the relevant legal framework entered into force. This includes the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports (ACRE agreement), the associated law (ACREA) and the ordinance (ACREO, Explanation ACREO (in German)). Multinationals in Switzerland are thus obliged to start drawing up a country-by-country report from the 2018 tax year. Switzerland can thus exchange country-by-country reports with the following partner states from 2020:
- Albania13
- Andorra7
- Anguilla16
- Antigua and Barbuda16
- Argentina3
- Armenia15
- Aruba10
- Australia1
- Austria4
- Azerbaijan9
- Bahamas16
- Bahrain16
- Barbados10
- Belgium1
- Belize8
- Bermuda16
- Brazil1
- British Virgin Islands16
- Bulgaria1
- Cameroon16
- Canada7
- Cayman Islands16
- Chile7
- China7
- Colombia1
- Costa Rica7
- Croatia7
- Curaçao7, 19
- Cyprus7
- Czech Republic5
- Denmark1
- Dominican Republic13
- Estonia4
- Faroe Island13
- Finland1
- France1
- Georgia14
- Germany1
- Gibraltar8
- Greece1
- Guernsey1
- Hong Kong8
- Hungary7
- Iceland4
- India1
- Indonesia3
- Ireland1
- Isle of Man1
- Israel10
- Italy1
- Japan1
- Jersey1
- Kazakhstan9
- Kenya11
- Korea1
- Latvia7,17
- Liberia16
- Liechtenstein1
- Lithuania1
- Luxembourg1
- Macao16
- Malaysia1
- Maledives10
- Malta1
- Mauritius7
- Mexico1
- Monaco7
- Mongolia13
- Montenegro16
- Montserrat16
- Netherlands1
- New Zealand1
- Nigeria9
- Norway1
- Oman16
- Pakistan2
- Panama7
- Peru8
- Poland2
- Portugal4
- Qatar16
- Romania16
- Russia18
- San Marino8
- Saudi Arabia7
- Senegal14
- Serbia16
- Seychelles6
- Singapore1
- Slovak Republic1
- Slovenia1
- South Africa1
- Spain1
- Sweden1
- Thailand12
- Trinidad and Tobago16
- Tunisia13
- Turkey8
- Turks and Caicos Islands16
- Ukraine13
- United Arab Emirate16
- United Kingdom1
- Uruguay5
- Vietnam16
1 Exchange as of June 2018 (including in Switzerland voluntarily submitted country-by-country reports)
2 Exchange as of September 2018 (including in Switzerland voluntarily submitted country-by-country reports)
3 Exchange as of December 2018 (including in Switzerland voluntarily submitted country-by-country reports)
4 Exchange as of March 2019 (including in Switzerland voluntarily submitted country-by-country reports)
5 Exchange as of June 2019 (including in Switzerland voluntarily submitted country-by-country reports)
6 Exchange as of December 2019 (including in Switzerland voluntarily submitted country-by-country reports)
7 Exchange as of 2020 (for tax periods as of 2018)
8 Exchange as of 2021 (for tax periods as of 2019)
9 Exchange as of 2022 (for tax periods as of 2020)
10 Exchange as of 2023 (for tax periods as of 2021)
11 Exchange as of 2024 (for tax periods as of 2022)
12 Exchange as of 2025 (for tax periods as of 2023)
13 Exchange as of 2026 (for tax periods as of 2024)
14 Exchange as of 2027 (for tax periods as of 2025)
15 Exchange as of 2028 (for tax periods as of 2026)
16 These partner states will only transmit and not receive country-by-country reports.
17 In Switzerland voluntarily submitted country-by-country reports for the tax period 2016 have been exchanged with Latvia in June 2018. Since then no further voluntary country-by-country reports have been exchanged with Latvia. Latvia has confirmed to Switzerland that multinational enterprise groups whose ultimate parent entity is resident in Switzerland are not required to file a country-by-country report in Latvia for tax periods 2016 and 2017.
18 Country-by-country reports for tax periods from 2018 until 2019 have been exchanged with Russia from 2020 until 2021. Data transmission to Russia is currently suspended.
19 It is currently not possible to exchange country-by-country reports data with this partner jurisdiction, as the Global Forum is investigating a possible security incident and has blocked data transmission until further notice.
The list of bilateral exchange relationships can also be viewed on the OECD website.
The Federal Tax Administration (FTA) is responsible for the implementation of the Country-by-Country Reporting.