Switzerland to exchange country-by-country reports on multinationals with more countries

By Davide Anghileri, University of Lausanne

Switzerland’s Federal Council, during its meeting of 17 October, decided to extend the exchange of country-by-country on multinationals to additional countries.

The exchange of country-by-country reports was an outcome of the 2015 OECD/G20 base erosion profit shifting (BEPS) plan, aimed at improving transparency with regard to the taxation of multinationals. As a result of the BEPS project, countries established a uniform framework for the exchange of the country-by-country reports.

In December 2017, Switzerland notified the OECD of its initial list of 108 countries with which it will exchange country-by-country reports. The list included all countries that signed the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports (ACRE agreement) or that, as of 1 December 2017, were members of the Inclusive Framework on BEPS, which is a coalition of nations committed to implementing the BEPS project outcomes.

Since December 2017, more states have signed the ACRE agreement or joined the Inclusive Framework on BEPS. The Swiss government therefore decided to include on its list of exchange partners all jurisdictions that have undertaken to implement the minimum standards resulting from the BEPS project.

Switzerland’s Federal Council also adopted an amendment to the Ordinance on the International Automatic Exchange of Country-by-Country Reports of Multinational Corporations to put it in line with the new guidelines, which have been supplemented and revised with further technical answers for the preparation and exchange of country-by-country reports.

The amendment will come into force 1 December 2018.

Davide Anghileri

Davide Anghileri

Researcher and lecturer at University of Lausanne

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.

Davide can be reached at [email protected].

Davide Anghileri
Davide can be reached at [email protected].

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