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 13.04.2018):

Argentina 

Germany

Malta

Australia1

Greece

Mauritius 

Austria 

Guernsey

Mexico

Belgium

Hungary 

Netherlands

Bermuda2 

Iceland 

New Zealand1

Brazil

India1

Norway1

Bulgaria1

Indonesia 

Pakistan

Canada 

Ireland1

Poland 

Cayman Islands2

Isle of Man

Portugal 

Chile 

Italy

Russia 

Colombia1

Japan

Singapore1

Croatia 

Jersey

Slovak Republic1

Cyprus2 

Korea

Slovenia

Czech Republic 

Latvia

South Africa1

Denmark

Liechtenstein

Spain

Estonia 

Lithuania1

Sweden1

Finland1

Luxembourg

United Kingdom1  

France1

Malaysia

Uruguay  

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 13.04.2018). 

2 These partner states will only transmit and not receive country-by-country reports (status as at 21.12.2017).

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 16.04.2018

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