Switzerland supports international efforts to achieve greater transparency and a level playing field with regard to the taxation of multinationals. As a member of the OECD, it actively participated in the base erosion and profit shifting (BEPS) project. The Federal Council has instructed the Federal Department of Finance (FDF) to deliver analyses and proposals for implementing the outcomes.
Some outcomes are regarded as new minimum standards with which all G20 and OECD member states undertake to comply. The minimum requirements concern country-by-country reports, criteria for taxing intangible property (patent boxes), the spontaneous exchange of information on advance tax rulings, access to the mutual agreement procedure for resolving disputes and the inclusion of anti-abuse clauses in double taxation agreements (DTAs). With the so-called inclusive framework, the OECD has established a control system to monitor member states' compliance with the minimum requirements.
With tax proposal 17, Switzerland should align its corporate tax law with international standards and abolish tax regimes which are no longer accepted internationally. In this way, the declaration of intent of the Federal Council and of the 28 EU member states of October 2014 will also be implemented. Switzerland is implementing the other minimum standards from the BEPS project as well: with regard to the spontaneous exchange of information on tax rulings, Switzerland has had the necessary legal basis since 1 January 2018 with the OECD/Council of Europe multilateral administrative assistance convention. The statutory basis for the exchange of country-by-country reports came into force on 1 December 2017. These country-by-country reports allow for a general overview of the worldwide distribution of multinationals' profits and taxes. Switzerland will implement the minimum standards concerning access to the mutual agreement procedure for resolving disputes and the inclusion of anti-abuse clauses in double taxation agreements (DTAs) by means of either the BEPS convention or bilateral revisions of its DTAs.
Last modification 19.02.2018