With the Federal act on the international automatic exchange of country-by-country reports of multinationals of June 16, 2017 (AECCR), Switzerland intends to implement one of the international standards of the base erosion and profit shifting project (BEPS). Indeed, this project’s objective is to improve transparency with regard to the taxation of multinationals and prevent such multinationals from abusing or misusing applicable double tax treaties. The Ordinance on the international automatic exchange of country-by-country reports of multinationals (OECCR) adopted by the Federal Council on September 29, 2017, notably specifies the content of the country-by-country reports and the threshold above which companies have to establish such reports.

It being specified that the referendum deadline expired on October 5, 2017, without a referendum being requested, l’AECCR and l’OECCR will enter into force on December 1, 2017. As a consequence, multinationals based in Switzerland and concerned by the AECCR and the OECCR will be obliged for the first time to establish a country-by-country report with respect to the 2018 tax year. Such reports will be exchanged between Switzerland and its partner states as from 2020.