At the end of June 2018, Switzerland’s Federal Tax Administration (FTA) will for the first time send multinational groups' country-by-country reports to 35 partner states within the framework of so-called country-by-country reporting.
Overall, the FTA will send 109 reports to a total of 35 states by the end of the month. Among other things, country-by-country reports contain information on the global allocation of income, taxes paid and the group's principal business activities in various countries. The content is confidential and subject to the principle of speciality.
This first exchange for the 2016 tax period is on a voluntary basis at the respective company's request. The submission of reports will be mandatory from the 2018 tax period onwards.
The scope and implementation of the exchange are based on the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports (CbC MCAA), which 69 states have signed so far.
It is not yet known whether the FTA will receive country-by-country reports from groups headquartered in the partner states at this time. The FTA will also receive reports from abroad from the 2018 tax period at the latest.
Companies abroad may be obliged to submit such reports. Individual companies are therefore voluntarily complying with the reporting obligation in Switzerland. The guarantees in accordance with the CbC MCAA thus apply.
The automatic exchange of country-by-country reports aims to combat base erosion and profit shifting (BEPS) and is the minimum standard of the G20 and OECD states.
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