On 18th October 2017 during its meeting, the Federal Council decided to bring a law on the International Automatic Exchange of Country-by-Country Reports of Multinationals into force on 1st December 2017. Under the new law, CbC reporting obligations shall apply to Swiss headquartered multinational groups with annual consolidated group revenue of at least €750m, which equals CHF 900m for the fiscal years (FYs) starting on or after 1 January 2018.
The Federal Council’s decision follows the expiration of a referendum deadline on 5th October without a referendum being called. Multinationals in Switzerland will thereby be obliged for the first time to draw up a country-by-country report from the 2018 tax year. The exchange of country-by-country reports between Switzerland and its partner states will therefore take place from 2020. Groups can voluntarily submit a country-by-country report for tax periods before 2018 which the Federal Tax Administration (FTA) can transmit on the basis of the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports to partner states from 2018. The country-by-country reports are formulated to help tax authorities determine whether there is a risk that a multinational will operate tax avoidance through incorrect transfer pricing or other means.
