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). Multinationals in Switzerland will thus be obliged to start drawing up a country-by-country report from the 2018 tax year. Switzerland will thus exchange country-by-country reports with the following partner states from 2020 and will be able to receive such reports from then at the latest:

Andorra8 Germany Netherlands
Argentina3 Greece New Zealand1
Australia1 Guernsey Nigeria11
Austria Hong Kong9 Norway1
Belgium Hungary8 Pakistan2
Bermuda11 Iceland Peru11
Brazil1   India1 Poland2
British Virgin Islands11 Indonesia3 Portugal4
Bulgaria13 Ireland1 Qatar11
Canada Isle of Man Romania11
Cayman Islands11 Italy Russia8
Chile Japan Saudi Arabia8
China8 Jersey Seychelles7
Colombia1 Korea1 Singapore1
Costa Rica11 Latvia8,12 Slovak Republic1
Croatia Liechtenstein Slovenia
Curaçao11 Lithuania1 South Africa1
Cyprus11 Luxembourg Spain
Czech Republic Malaysia Sweden1
Denmark Malta Turks and Caicos Islands11
Estonia4 Mauritius8 United Arab Emirates9
Finland1 Mexico United Kingdom1  
France1 Monaco8 Uruguay5   

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 September 2019 (including in Switzerland voluntarily submitted country-by-country reports)

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

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

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

10 Exchange as of 2022 (for tax periods as of 2020)

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

12 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.

 13 In Switzerland voluntarily submitted country-by-country reports for the tax periods 2016 and 2017 have been exchanged with Bulgaria from June 2018 until June 2019. Since then Bulgaria receives no further country-by-country reports, but continues to transmit them to Switzerland. Switzerland will transmit country-by-country reports (including in Switzerland voluntarily submitted country-by-country reports) to Bulgaria at a later stage, once Bulgaria meets again the conditions for receipt. Bulgaria has confirmed to Switzerland that multinational enterprise groups whose ultimate parent entity is resident in Switzerland and have submitted the country-by-country report in Switzerland are not required to file a country-by-country report in Bulgaria.

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 03.03.2020

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