On 25 January 2022 Switzerland’s State Secretariat for International Financial Matters published its summary for 2021 entitled: Swiss financial and tax centre in 2021: more sustainable, more digital and in good shape despite the pandemic. The review covers the main developments in Switzerland in relation to international financial and tax matters.
The State Secretariat for International Finance represents Switzerland‘s interests on issues concerning finance and taxation, engaging with partner countries and international organisations.
The review emphasises Switzerland’s innovative digital technology, noting that on 1 August 2021 the new blockchain/Distributed Ledger Technology (DLT) legislation came into force.
The review notes that Switzerland is participating in the OECD’s Inclusive Framework which has agreed the main outline of the new rules for taxation of large multinationals, including the 15% global minimum tax rate. Switzerland emphasises the need for legal certainty and the importance of avoiding multiple special rules for individual jurisdictions which could harm innovative countries with small domestic markets. The report notes that Switzerland favours rules that encourage innovation and prosperity, and are applied on a uniform basis with a mechanism for dispute resolution.
The report emphasises that Switzerland is willing to collaborate with other financial centres such as Singapore and London, where there are common interests, and that there is healthy competition between these jurisdictions.
The review notes that Switzerland participates in international efforts to combat money laundering and terrorist financing and implements recommendations of the Financial Action Task Force (FATF). On 19 March 2021, Parliament approved amendments to the Anti-Money Laundering Act, implementing important FATF recommendations to counter money laundering and terrorist financing. New requirements have been introduced for financial intermediaries in relation to beneficial ownership, updating client data and reporting suspicions of money laundering.
Switzerland has concluded double tax treaties with more than 100 other jurisdictions. A new treaty was signed with Ethiopia in 2021, and tax treaties with Bahrain, Brazil and Saudi Arabia entered into force. Protocols were signed in the year to amend tax treaties with Armenia, Japan and North Macedonia and protocols amending treaties with Cyprus, Liechtenstein and Malta entered into force during the year.
Switzerland has been automatically exchanging information on financial accounts with other jurisdictions since 2017. During 2021, information on around 3.3 million financial accounts was sent to 96 other jurisdictions while Switzerland received information on around 2.1 million accounts sent from other countries. On 3 December 2021, the Federal Council began consulting with twelve other jurisdictions on the automatic exchange of information.
Country-by-country (CBC) reports submitted by multinational groups were exchanged with 81 partner jurisdictions in 2021 and the OECD considers that Switzerland is compliant with the standard on CbC reporting.
In the reference year of 2020, Switzerland completed a total of 181 mutual agreement procedures (MAPS). The OECD has noted the efficiency of MAPs in Switzerland in relation to transfer pricing.
