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 Netherlands1
Anguilla14 Gibraltar8 New Zealand1
Argentina3 Greece1 Nigeria9
Aruba10 Guernsey1 Norway1
Australia1 Hong Kong8 Oman14
Austria4 Hungary7 Pakistan2
Azerbaijan9 Iceland4 Panama7
Bahamas, The14 India1 Peru8
Bahrain14 Indonesia3 Poland2
Barbados10 Ireland1 Portugal4
Belgium1 Isle of Man1 Qatar14
Belize14 Israel10 Romania14
Bermuda14 Italy1 Russia16
Brazil1 Japan1 San Marino8
British Virgin Islands14 Jersey1 Saudi Arabia7
Bulgaria1 Kazakhstan9 Seychelles6
Canada7 Kenya11 Singapore1
Cayman Islands17 Korea1 Slovak Republic1
Chile7 Latvia7,15 Slovenia1
China7 Liberia14 South Africa1
Colombia1 Liechtenstein1 Spain1
Costa Rica17 Lithuania1 Sweden1
Croatia7 Luxembourg1 Thailand12
Curaçao14 Macao14 Tunisia14
Cyprus7 Malaysia1 Turkey8
Czech Republic5 Maledives10 Turks and Caicos Islands14
Denmark1 Malta1 United Arab Emirate14
Estonia4 Mauritius7 United Kingdom1
Faroe Island13 Mexico1 Uruguay5
Finland1 Monaco7  
France1 Montserrat14  

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

15 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.

16 Country-by-country reports for tax periods from 2018 util 2019 have been exchanged with Russia from 2020 until 2021. Data transmission to Russia is currently suspended.

17 Up to and including the tax period 2022, Costa Rica only transmits and does not receive country-by-country reports. From tax period 2023, (exchange as of 2025), Switzerland and Costa Rica exchange reciprocally country-by-country reports.

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 25.03.2024

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