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Swiss CbC Reporting Regime Wins OECD Approval

Friday, September 13, 2019

Switzerland's country-by-country reporting regime meets international standards and the country effectively exchanges the reports it receives with other countries, an OECD peer review has concluded.

CbC reporting, one of the four minimum standards of the BEPS Project, requires tax administrations to collect and share detailed information on all large MNEs doing business in their country. Information collected includes the amount of revenue reported, profit before income tax, and income tax paid and accrued, as well as the stated capital, accumulated earnings, number of employees and tangible assets, broken down by jurisdiction.

The peer review process is happening in three annual reviews, with the third taking place in 2019.

The OECD has released its findings on Switzerland's regime following a second phase review. The OECD stated that Switzerland's implementation of the Action 13 minimum standard meets all the applicable terms of reference.

Switzerland introduced a CbC reporting obligation for fiscal years commencing on or after January 1, 2018. It also allowed Switzerland-headquartered multinational groups to file a CbC report on a voluntary basis, for fiscal years beginning between January 1, 2016 and December 31, 2017.

The peer review noted that Switzerland has primary and secondary law in place for implementing the minimum standard establishing the necessary requirements, including the filing and reporting obligations. It said that Switzerland meets all the terms of reference relating to the domestic legal and administrative framework.

The review also noted that Switzerland has the necessary processes in place to ensure the proper exchange of CbC report information with other territories and meets all the terms of reference relating to the appropriate use of CbC reports.