The automatic exchange of country-by-country reports is a minimum standard of the base erosion and profit shifting (BEPS) project of the G20 and OECD countries. The objective of the BEPS project is to improve transparency with regard to the taxation of multinationals and to establish a uniform framework for the exchange of the reports.

The legal basis for the exchange of country-by-country reports entered into force for Switzerland on 1 December 2017. On the same day, Switzerland notified the OECD of the 108 countries with which it will exchange country-by-country reports. These are all countries that have signed the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports (ACRE agreement) or that were members of the Inclusive Framework on BEPS on 1 December 2017. The Inclusive Framework comprises all states that have undertaken to implement the minimum standards resulting from the BEPS project.

Since other states have signed the ACRE agreement or joined the Inclusive Framework on BEPS since 1 December 2017, the Federal Council decided today to submit an updated list of countries to the OECD in December 2018. At the time of submission, the list should contain all countries that meet the criteria mentioned above.

In addition, the Federal Council decided to amend the ACREO because the current ordinance refers to the OECD guidelines of 6 September 2017. These guidelines have been supplemented and revised with further technical answers for the preparation and exchange of country-by-country reports in the meantime. The amendment will come into force on 1 December 2018.

Federal Council extends list for exchange of country-by-country reports and amends ordinance