Taxation

Double taxation agreements (DTAs) prevent double taxation and facilitate cross-border economic transactions. In addition, DTAs usually contain certain bans on discrimination, a dispute resolution mechanism and a clause on the exchange of information upon request.

On 1 January 2017, the OECD/Council of Europe Convention on Mutual Administrative Assistance in Tax Matters (administrative assistance convention) entered into force for Switzerland. This makes provision for the obligation to provide spontaneous administrative assistance in Article 7. For the purposes of spontaneous administrative assistance, the convention will be applicable in Switzerland for tax periods from 1 January 2018.

The exchange of information upon request refers to the exchange of information between tax authorities further to a request for administrative assistance. The basis is formed by bilateral agreements and the administrative assistance convention.

With the help of the global standard for the automatic exchange of information on financial accounts (AEOI) tax transparency should be increased and cross-border tax evasion and should be prevented. The global standard 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 and territories, including all major financial centres, have adopted the standard.

With the exchange of country-by-country reports is Switzerland implementing a minimum standard of the G20 countries and the OECD to combat base erosion and profit shifting (BEPS).

In July 2020, the Organisation for Economic Co-operation and Development (OECD) adopted Model Rules for the automatic exchange of information (AIA) on natural persons and legal entities that earn their income by offering services via online platforms. In June 2021, the Model Rules were expanded. The Model Rules are not binding for the countries.

Switzerland supports international efforts to achieve greater transparency and a level playing field with regard to the taxation of multinationals. As a member of the OECD, it actively participates in the base erosion and profit shifting (BEPS) project and follow-up work.