Swiss citizens this month voted “no” on the proposed “Corporate Tax Reform III” and now, one question being asked is: What does this mean for Switzerland’s position on and with regards to implementation of BEPS (base erosion and profit shifting)?
Generally speaking, there is very little or no direct impact of the vote on BEPS, and in particular BEPS Action 13 and the country-by-country (CbC) reporting is not affected at all. For purposes of implementing CbC reporting, Switzerland’s government must proceed with and see that a new law on the international automatic exchange of CbC reports of multinationals (ALBA-Gesetz) becomes effective, ideally in 2017. For that, the parliamentary debates must be completed, and the referenda period must elapse so that the law does not become subject to a referendum vote.
While the vote on the corporate tax reform means that business once again must deal with some uncertainty, there is no uncertainty regarding the implementation of the BEPS actions in Switzerland. The implementation of the minimum standards as set out in the “inclusive framework for the implementation of the BEPS package” as signed up by Switzerland and covering harmful tax practices (Action 5), tax treaty abuse (Action 6), country-by-country reporting (Action 13) as well as improvements in cross-border tax dispute resolution (Action 14) is generally still on track.
Read a February 2017 blog item posted by the KPMG member firm in Switzerland
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