Exchange of tax-related information
Tax authorities exchange information, e.g. on financial accounts and advance tax rulings, in order to increase transparency and prevent cross-border tax evasion. The exchange of information in accordance with international standards takes place upon request, spontaneously or automatically.
Exchange of information upon request
The rules on the exchange of tax-related information upon request are set out in bilateral double taxation agreements (DTAs). The corresponding OECD international standard is decisive. Switzerland is prepared to agree on a provision on the exchange of information upon request according to the international standard in all DTAs. Implementation of the exchange of information upon request is reviewed by the Global Forum on Transparency and Exchange of Information for Tax Purposes.
Spontaneous exchange of information
Information is spontaneously exchanged between tax authorities when the transmitting state suspects that information may be of interest to another state. In this context, spontaneous means that no request was submitted beforehand. The first spontaneous exchange of information took place within the framework of the OECD/G20 project on base erosion and profit shifting (BEPS). This concerns advance tax rulings where there is a risk of base erosion or profit sharing. Switzerland has been spontaneously exchanging information on advance tax rulings since 2018.
Automatic exchange of information
As part of the automatic exchange of information, partner states regularly provide each other with information on financial accounts, as well as country reports, for example.
The OECD's global standard for the automatic exchange of financial account information (AEOI) is designed to increase tax transparency and prevent cross-border tax evasion. It makes provision for the mutual exchange of information on financial accounts between states and territories that have agreed among themselves to the AEOI. Aside from Switzerland, over 100 states, including all major financial centres, have undertaken to adopt the standard.
The exchange of country-by-country reports aims to combat base erosion and profit shifting. With the adoption of the corresponding standard, multinationals in Switzerland are obliged to prepare a country-by-country report from the 2018 tax year onwards. Switzerland then exchanges the reports with its partner states.
Further information on the topic can be found on the website of the State Secretariat for International Finance SIF