Switzerland: country-by-country report exchange enters into force

by Davide Anghileri

Switzerland’s Federal Council, during its meeting of 18 October, decided to bring into force a law on the international automatic exchange of country-by-country reports of multinationals commencing 1 December.

The Federal Council’s decision follows the expiration of a referendum deadline on 5 October without a referendum being called.

The country-by-country reports are designed to help tax authorities determine if there is a risk that a multinational group is engaging in tax avoidance through incorrect transfer pricing or other means.

Hence, large multinationals in Switzerland would be obliged for the first time to draw up a country-by-country report from the 2018 tax year. The exchange of country-by-country reports between Switzerland and its partner states would take place from 2020.

Switzerland also disclosed a list of 101 countries with which it will exchange the country-by-country reports.

In this regard, must be borne in mind that the exchange of information will not be applicable between Switzerland and another state until the other state has also included Switzerland on its list.

In any case, groups can voluntarily submit a country-by-country report for tax periods before 2018, which the Federal Tax Administration can transmit to partners states on the basis of the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports.

Davide Anghileri

Davide Anghileri is a PhD candidate at the University of Lausanne, where he is writing his thesis on the attribution of profits to PEs. He researches transfer pricing issues and lectures for the Master of Advanced Studies in International Taxation and Executive Program on Transfer Pricing.

Anghileri, a Contributing Editor at MNE Tax, previously worked as a policy advisor to the Swiss government on BEPS issues. He can be reached at danghileri@yahoo.it.

Davide Anghileri


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