Switzerland launches consultation on exchange of multinational corporation country-by-country tax reports

Switzerland’s Federal Council on March 13 initiated a consultation on legislation that would give effect to a multilateral agreement signed by Switzerland to implement OECD/G20 base erosion profit shifting (BEPS) plan outcomes on transfer pricing documentation and country-by-country reporting.

Switzerland was among 31 nations that signed the Multilateral Agreement on the Exchange of Country-by-Country Reports on January 27 to implement BEPS agreements. The new scheme is designed to give tax administrations greater insight into the tax and transfer pricing positions of large multinationals.

The plan requires MNEs to annually file country-by-country reports with tax administrations and establishes a framework for exchanging the reports with other tax administrations. The goverment said that about 200 MNEs resident in Switzerland would be affected by the legislation.

If the legislation is approved, multinationals in Switzerland would file country-by-country reports beginning 2018, with the first automatic exchange occurring in 2020, the Federal Council said.

The goverment said it will transmit to other countries any country-by-country report voluntarily submitted by an MNE prior to 2018.

The consultation will run until July 13.

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