At its meeting on 18 October 2017, the Federal Council decided to bring the Federal Act on the International Automatic Exchange of Country-Based Reports by Multinational Corporations (ALBAAG) into force on 1 December 2017 (see also our contribution of 1 October 2017 regarding ALBAV). The entry into force of the multilateral agreement of the competent authorities on the exchange of country-specific reports of 27 January 2016 (ALBA agreement) is also scheduled for December.
The referendum deadline expired unused on 5 October 2017, which means that multinational companies in Switzerland will be obliged to prepare a country-specific report for the first time from the 2018 tax year. Switzerland and its partner states will thus exchange country-specific reports from 2020 onwards.
The Federal Council has also adopted a list of countries with which Switzerland will exchange country-specific reports. However, the ALBA agreement is only applicable if the other state has also included Switzerland on its list.
For the tax periods of 2016 and 2017, groups can voluntarily submit a country-specific report. In this regard, the Federal Council has adopted a declaration on the Administrative Assistance Convention, whereby the Administrative Assistance Convention and the guarantees contained therein are applicable for the 2016 and 2017 fiscal years.
The press release and other documents are available here.
