Switzerland - First CbCR Exchange Of Large MNEs

; posted on
June 21st, 2018

After the exchange of advanced tax rulings with partner jurisdictions, the Swiss Federal Tax Administration (FTA) is about to send its first multinational groups’ Country-by-Country reports (CbCR) to 35 partner states within the CbCR framework at the end of June, 2018.

Content of Exchange

109 reports will be sent to the 35 partner states by FTA in this exchange of information. The reports contain information on the global allocation of income, taxes paid and the group’s principal business activities in various countries. It’s a unilateral exchange by Switzerland. It’s not yet known whether the FTA will receive country-by-country reports from other partner states which groups headquartered in at this time, but FTA will receive reports from abroad for the 2018 tax period at the latest. The content will be confidential and subject to the principle of speciality.

Obligation of Multinational Companies

It’s voluntary for companies to exchange the reports for the 2016 tax period in this time. The submission of reports will be mandatory from the 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). 69 states have signed this agreement so far. Companies outside Switzerland 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.

Sources: Switzerland Federal Department of Finance

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