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
© 2018 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of independent firms are affiliated with KPMG International. KPMG International provides no client services. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. All rights reserved.
The KPMG logo and name are trademarks of KPMG International. KPMG International is a Swiss cooperative that serves as a coordinating entity for a network of independent member firms. KPMG International provides no audit or other client services. Such services are provided solely by member firms in their respective geographic areas. KPMG International and its member firms are legally distinct and separate entities. They are not and nothing contained herein shall be construed to place these entities in the relationship of parents, subsidiaries, agents, partners, or joint venturers. No member firm has any authority (actual, apparent, implied or otherwise) to obligate or bind KPMG International or any member firm in any manner whatsoever. The information contained in herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 4366, 1801 K Street NW, Washington, DC 20006.