The Swiss Federal Council in late September 2017 adopted an ordinance concerning the international exchange of country-by-country (CbC) reports of multinational entities (MNEs). Without a referendum being called until 5 October 2017, the CbC reporting measures can satisfy the requirement for an effective date of December 2017.
The filing of a CbC report will become mandatory for the first time from the tax year 2018 onwards, and the exchange of CbC reports between Switzerland and those partner states or countries that have signed the multilateral competent authority agreement (MCAA) will be mandatory from 2020 onwards.
Voluntary filing of CbC reports for the 2016 tax year is available for Swiss-based MNEs beginning 1 November 2017.
The Swiss federal tax administration has published guidance about how and when to Swiss MNEs are to submit CbC reports for fiscal year 2016 to the tax administration. Swiss MNEs can submit their CbC reports beginning from 1 November 2017 until the end of a 12-month period after the end of the financial year of the group.
Switzerland adopted the global minimum standard included in Action 13 of the OECD base erosion and profit shifting (BEPS) project for the international automatic exchange of country-by-country reports with quantitative as well as qualitative data of MNEs with an annual consolidated turnover of €750 million or more. However, the timing for the actual application of this standard by Switzerland and Swiss MNEs remained uncertain because it was generally expected that the first international automatic exchange of CbC reports based on FY2016 would not be exchanged until the end of June 2018.
Read an October 2017 blog item posted by the KPMG member firm in Switzerland.
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