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 (status as at 31.07.2018).

Argentina 

Greece

Mexico

Australia1

Guernsey

Netherlands

Austria 

Hungary 

New Zealand1

Belgium

Iceland 

Norway1

Brazil1  

India1

Pakistan1

Bulgaria1

Indonesia 

Poland1

Canada 

Ireland1

Portugal 

Cayman Islands2

Isle of Man

Romania2

Chile 

Italy

Russia 

Colombia1

Japan

Singapore1

Costa Rica2

Jersey

Slovak Republic1

Croatia 

Korea1

Slovenia

Cyprus2

Latvia

South Africa1

Czech Republic 

Liechtenstein

Spain

Denmark

Lithuania1

Sweden1

Estonia 

Luxembourg

United Kingdom1  

Finland1

Malaysia

Uruguay  

France1

Malta

 

Germany

Mauritius

 

1 Switzerland will also be able to transmit voluntarily submitted country-by-country reports for the tax periods 2016 and 2017 to these partner states (status as at 31.07.2018).

2 These partner states will only transmit and not receive country-by-country reports (status as at 31.07.2018).

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.

Further information

Last modification 02.08.2018

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