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 (status as at 28.01.2019):
|Chile8||Isle of Man1||Qatar11|
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.
The list of bilateral exchange relationships can also be viewed on the OECD website.
Multinationals can voluntarily submit a country-by-country report for the 2016 and 2017 fiscal years, and the Federal Tax Administration will transfer it to the partner states from 2018.
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.
Last modification 08.03.2019