The Swiss Federal Council published draft law with respect to Country-by-Country reporting for consultation on 13 April 2016. The draft law is based on the recommendations contained in the OECD BEPS Action Plan 13 (“Transfer Pricing Documentation and Country-by-Country Reporting”). The Swiss Federal Council has published draft legislation on country-by-country reporting for tax purposes. As per the draft legislation, CbC reporting obligations shall apply to Swiss headquartered multinational groups with annual consolidated group revenue of at least €750m, which equals CHF 900m. It is expected that the new law will enter into force effective from the fiscal years beginning on or after 1 January 2018.
Swiss groups will be permitted to file a CbC report for fiscal years 2016 and 2017 with the Swiss Federal Tax Administration (SFTA) for exchange purposes on a voluntary basis.
