The Swiss Federal Tax Administration (FTA) will exchange this month 109 country-by-country (CbC) reports of multinational enterprises’ (MNEs) with 35 foreign tax jurisdictions.
According to the FTA, 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 FTA noted that the content is confidential and subject to the principle of speciality.
CbC reporting is part of a three-tiered approach to transfer pricing documentation (along with “master” and “local” files) developed under base erosion and profit shifting (BEPS) Action 13. The reports will contain key information such as the annual income and profits, as well as the capital, employees, and activities of multinationals.
According to the OECD, there are over 1,400 automatic exchange relationships in place among tax administrations committed to exchanging CbC reports as of mid-2018.
The scope and implementation of the exchange are based on the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports, which 70 countries, including Switzerland, have signed so far.