With the help of the global standard for the automatic exchange of information on financial accounts (AEOI) tax transparency should be increased and cross-border tax evasion and should be prevented. The global standard makes provision for the mutual exchange of information on financial accounts between states and territories that have agreed among themselves to the AEOI. Aside from Switzerland, over 100 states and territories, including all major financial centres, have declared their intention to adopt the standard.
Switzerland usually implements the AEOI according to the Multilateral Competent Authority Agreement on the Automatic Exchange of Financial Account Information (MCAA). Bilateral treaties on the AEOI have been concluded with the EU, Hong Kong and Singapore.
The legal basis for the AEOI entered into force on 1 January 2017. The Federal Tax Administration (FTA) is responsible for the implementation of the AEOI.
The list of the activated bilateral exchange relationships of all states and territories can be viewed on the OECD website. The following list contains the AEOI partner states of Switzerland. It is kept regularly up to date and has priority over the list of the OECD:
||Approval1||Entry into force2|
|Antigua and Barbuda4||17.040||01.01.2019|
|British Virgin Islands3||17.040||01.01.2018|
|China (People's Republic)||17.040||01.01.2018|
|Isle of Man||16.057||01.01.2017|
|Overseas municipalities of the NL (Bonaire, Saint Eustatius, Saba)||18.055||01.01.2019|
|Saint Kitts and Nevis||17.040||01.01.2018|
|Saint Vincent and the Grenadines5||17.040||01.01.2018|
|Sint Maarten5||19.033||still open9|
|Trinidad and Tobago5||19.033||still open9|
|Turks und Caicos Islands3||17.040||01.01.2018|
|United Arab Emirates3||17.040||01.01.2019|
1: Item number for parliamentary deliberations.
2: From the date of entry into force on 1 January of a certain year a jurisdiction is considered as a participating jurisdiction. Since then the financial institutions subject to the reporting requirement will collect – with the reservations of notes 3 and 4 – account information concerning persons resident for tax purposes in the respective partner jurisdictions from this date. This information will be exchanged between the competent authorities for the first time in the following year.
3: These jurisdictions have declared themselves to be "permanent non-reciprocal jurisdictions", i. e. they will supply account information to the partner jurisdictions on a permanent basis but will not receive such data.
4: As the convention on the mutual administrative assistance in tax matters entered into force in 2019 in these partner jurisdictions, it is applicable to taxable periods beginning on or after 1 January 2020. Therefore, the first exchange of information will be carried out in 2021.
5: These partner jurisdictions must implement a Global Forum action plan on confidentiality and data security. There will be no reciprocal exchange of data until this action plan has been successfully implemented. Reporting Swiss financial institutions must nevertheless collect the relevant data from the time of activation of the AEOI and forward it to the Federal Tax Administration by the specified deadline. The FTA will transmit this data to the partner jurisdictions only if they have satisfactorily implemented their action plan and an updated Global Forum review has confirmed this.
6: The bilateral AEOI agreement with the EU applies for all 27 EU member states and is also applicable for the Åland Islands, the Azores, French Guiana, Guadeloupe, the Canary Islands, Madeira, Martinique, Mayotte, La Réunion and Saint Martin.
7: The exchange of data with Bulgaria and Romania is currently suspended, as these countries do not meet or do not comply with the confidentiality/data security requirements. These countries will not receive data from AEOI partners until the problems have been solved and the Global Forum on Transparency and Exchange of Information for Tax Purposes (Global Forum) has confirmed the corrective measures.
8: Switzerland implements the AEOI with Hong Kong and Singapore on the basis of specific bilateral agreements.
9: These states and territories do not yet fulfil the conditions for activating the AEOI. The rights and obligations arising from the agreements are therefore not effective. In particular, there is no obligation on the reporting financial institutions to collect financial account information and transmit it to the competent authority. Switzerland will only notify these states and territories as AEOI partners once they meet the requirements of the global AEOI standard and declare their interest in introducing the AEOI with Switzerland. The AEOI is always activated on 1 January of each year.
10: Following the United Kingdom's withdrawal from the EU, the situation with regard to the AEOI is as follows:
- Until the end of the transitional period, EU agreements with third countries, such as the bilateral AEOI agreement between Switzerland and the EU, continue to apply to the United Kingdom.
- At the end of the transitional period, the AEOI will be implemented from 1 January 2021 on the basis of the multilateral AEOI agreements (Administrative Assistance Agreement in Tax Matters and MCAA).
Last modification 20.08.2020