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 adopted 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.
Status as at 07.04.2021
Vanuatu: temporarily non-reciprocal since 01.01.2021 (previously: permanent non-reciprocal)
Peru: new on the list
Albania: non-reciprocal, entry into force 01.01.2021
Costa Rica: reciprocal
Brunei Darussalam: entry into force 01.01.2021
Nigeria: non-reciprocal, entry into force 01.01.2021
||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 in the following year.
3: These jurisdictions have declared themselves to be "permanent non-reciprocal jurisdictions", i. e. they supply account information to the partner jurisdictions on a permanent basis but do 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 states and territories have declared themselves as "temporary non-reciprocal jurisdictions", i.e. they will initially provide information on financial accounts but will not receive such information until they meet the requirements of the AEOI standard in the area of confidentiality and data safeguard. Reporting Swiss financial institutions must collect the relevant data from the time of activation of AEOI and forward them to the Federal Tax Administration within the specified period. However, the Federal Tax Administration will only forward this data to the partner states if they fulfil the conditions for reciprocal data exchange and if an updated audit by the Global Forum confirms 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: The AEOI with the UK is implemented from 1 January 2021 on the basis of the multilateral AEOI agreements (Administrative Assistance Agreement in Tax Matters and MCAA).