During its meeting of November 23, 2016, the Swiss Federal Council adopted a dispatch on the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports and the Federal Decree required for the implementation thereof.

 

Switzerland is thereby implementing the minimum standard of the G20 countries and the OECD to combat base erosion and profit shifting (BEPS). In order to implement the automatic exchange of country-by-country reports in Switzerland, the following legal bases must exist:

·   the OECD/Council of Europe Convention on Mutual Administrative Assistance in Tax Matters which was adopted by Parliament on 18 December 2015. It will enter into force on 1 January 2017 and will be applicable for Switzerland from 1 January 2018;

·   the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports signed by Switzerland on 27 January 2016 which the Swiss Federal Council is submitting to Parliament with this proposal for approval;

·   the Swiss Federal Act on the International Automatic Exchange of Country-by-Country Reports of Multinationals which the Federal Council is also submitting to Parliament with this proposal.

 

According to a press release issued by the Swiss Federal Council, if the Swiss Parliament approves the proposal and no referendum is held, the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports and the Federal Act on the International Automatic Exchange of Country-by-Country Reports of Multinationals could enter into force at the end of 2017. Multinationals in Switzerland would thereby be obliged for the first time to draw up a country-by-country report for the 2018 tax year. According to the press release, the exchange of country-by-country reports between Switzerland and its partner states could therefore take place in 2020. At the same time as the Federal Act on the International Automatic Exchange of Country-by-Country Reports of Multinationals comes into force, the Swiss Federal Council will determine with which countries Switzerland wishes to exchange data.

 

In the press release it is also stated that so long as the legal bases enter into force at the end of 2017, multinational groups can submit a country-by-country report if they so wish for tax periods before 2018. The Act provides that the Federal Tax Administration (FTA) can transmit these reports on the basis of the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports to partner states from 2018.

 

Click on the language of your choice to be forwarded to the message to approve the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports and the implementation thereof in that language. (German, French or Italian)

 

Click on the language of your choice to be forwarded to the federal decree approving the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports and the implementation thereof in that language. (German, French or Italian)

 

Click on the language of your choice to be forwarded to a Report prepared by the Swiss Federal Department of Finance regarding the results of a consultation held regarding the MCAA on the exchange of CbC Reports in that language. (German, French or Italian)

 

Click on the language of your choice to be forwarded to a Report prepared by the Swiss Federal Department of Finance regarding the results of a consultation held regarding the MCAA on the exchange of CbC Reports in that language. (German, French or Italian)

 

Click on the language of your choice to be forwarded to the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports in that language. (German, French or Italian)

 

Click on the language of your choice to be forwarded to the proposal for a Federal law on the automatic international exchange of Country-by-Country Reports of multinational enterprises. (German, French or Italian)

 


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