Federal Council adopts Ordinance on International Automatic Exchange of country-by-country reports

Bern, 29.09.2017 - During its meeting on 29 September 2017, the Federal Council adopted the Ordinance on the International Automatic Exchange of Country-by-Country Reports of Multinationals. The Ordinance will come into force on 1 December 2017.

The Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports of 27 January 2016 and the Federal Act on the International Automatic Exchange of Country-by-Country Reports of Multinationals of 16 June 2017 form the legal basis for the exchange of the country-by-country reports. Switzerland is thereby implementing one of the global minimum standards of the base erosion and profit shifting (BEPS) project. The objective of this project is to improve transparency with regard to the taxation of multinationals and to establish a uniform framework for the exchange of the reports.

If the referendum deadline expires on 5 October 2017 without a referendum being called, the agreement and the act can enter into force in December 2017. Multinationals in Switzerland will thereby 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 will therefore take place from 2020. Groups can voluntarily submit a country-by-country report for tax periods before 2018 which the Federal Tax Administration (FTA) can transmit on the basis of the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports to partner states from 2018.

The Ordinance on the International Automatic Exchange of Country-by-Country Reports of Multinationals contains the Federal Council's implementing provisions for the Act mentioned. It specifies the content of the country-by-country reports and the threshold above which companies have to draw up country-by-country reports. In addition, it contains further implementing provisions, for example on the tasks of the Federal Tax Administration (FTA).

The Federal Council adopted the Ordinance on the International Automatic Exchange of Country-by-Country Reports of Multinationals before the expiry of the referendum deadline so that companies who wanted to submit a country-by-country report for 2016 could prepare themselves.

Address for enquiries

Frank Wettstein, Communications, State Secretariat for International Financial Matters SIF
Tel. +41 58 462 38 56, frank.wettstein@sif.admin.ch