FTA sends country-specific reports from multinational corporations for the first time (June 2018)
Silvia Hunziker
Marco Gehrig
At the end of June, the Swiss Federal Tax Administration (FTA) will for the first time send country-specific reports from multinational corporations to 35 partner states. The reports are sent as part of the so-called country-by-country reporting. By the end of June, the FTA will have sent a total of 109 reports to 35 countries. The country-specific reports contain, among other things, information on the worldwide distribution of income, the taxes paid and the most important economic activities of the Group in various countries. The content is confidential and subject to the principle of speciality.
This first exchange for the 2016 tax period will be voluntary at the request of the respective company. The scope and implementation of the exchange is based on the Multilateral Agreement between the competent authorities on the exchange of country-specific reports (ALBA Agreement), to which 69 countries have so far signed up. It is not yet known whether the FTA, for its part, will receive country-specific reports from groups based in the partner states. From the 2018 tax period at the latest, the FTA will also receive reports from abroad. Under certain circumstances, companies abroad are obliged to submit such reports. Individual companies therefore comply with the reporting obligation voluntarily in Switzerland. Thus, the guarantees under the ALBA agreement apply. The automatic exchange of country-specific reports serves to combat base erosion and profit shifting (BEPS) and represents the minimum standard of the G20 and OECD countries.
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Media release FTA of 18.6.2018, First exchange of country-specific reports from large multi-national companies