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 (PDF, 163 kB, 01.08.2023) 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:

Andorra7 Germany1 New Zealand1
Anguilla12 Gibraltar8 Nigeria9
Argentina3 Greece1 Norway1
Australia1 Guernsey1 Oman12
Austria4 Hong Kong8 Pakistan2
Azerbaijan9 Hungary7 Panama7
Bahamas, The12 Iceland4 Peru8
Bahrain12 India1 Poland2
Barbados10 Indonesia3 Portugal4
Belgium1 Ireland1 Qatar12
Belize12 Isle of Man1 Romania12
Bermuda12 Israel10 Russia14
Brazil1 Italy1 San Marino8
British Virgin Islands12 Japan1 Saudi Arabia7
Bulgaria1 Jersey1 Seychelles6
Canada7 Kazakhstan9 Singapore1
Cayman Islands12 Korea1 Slovak Republic1
Chile7 Latvia7,13 Slovenia1
China7 Liechtenstein1 South Africa1
Colombia1 Lithuania1 Spain1
Costa Rica12 Luxembourg1 Sweden1
Croatia7 Macao12 Thailand11
Curaçao12 Malaysia1 Tunisia12
Cyprus7 Maledives10 Turkey8
Czech Republic5 Malta1 Turks and Caicos Islands12
Denmark1 Mauritius7 United Arab Emirate12
Estonia4 Mexico1 United Kingdom1
Finland1 Monaco7 Uruguay5
France1 Netherlands1  

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)

Exchange as of December 2018 (including in Switzerland voluntarily submitted country-by-country reports)

Exchange as of March 2019 (including in Switzerland voluntarily submitted country-by-country reports)

Exchange as of June 2019 (including in Switzerland voluntarily submitted country-by-country reports)

Exchange as of December 2019 (including in Switzerland voluntarily submitted country-by-country reports)

Exchange as of 2020 (for tax periods as of 2018)

Exchange as of 2021 (for tax periods as of 2019)

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 2025 (for tax periods as of 2023)

12 These partner states will only transmit and not receive country-by-country reports.

13 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 country-by-country reports are 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.

14 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.

The list of bilateral exchange relationships can also be viewed on the OECD website.

What is a country-by-country report? 

Country-by-country reports provide information on how the turnover generated and the taxes paid by a multinational group of companies are distributed globally. Furthermore, they contain information on the most important economic activities of the multinational in the individual countries. These reports have to be drawn up by multinationals with an annual consolidated turnover of more than EUR 750 million or the equivalent in the national currency as of 1 January 2015. Approximately 200 groups established in Switzerland are likely to be concerned. 

Country-by-country reports will be transmitted automatically on an annual basis to the tax authorities of the countries where these groups have business units so long as a bilateral foundation for the exchange exists. The data is directed exclusively at tax authorities and will not be published.

Swiss business units of groups which are domiciled abroad can be obliged to submit a country-by-country report in Switzerland in certain cases. However, as Switzerland indicated in the dispatch of 23 November 2016, this obligation will be restricted to cases for which the OECD Model Law makes provision for in the report on BEPS action 13.

Further information

Last modification 26.09.2023

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