Since 2017, the automatic exchange of information (AEOI) between Switzerland and the EU has been implemented by means of the AEOI agreement. The protocol of amendment adapts the AEOI agreement to the revised OECD standard, which Switzerland will implement from 2026.
The protocol of amendment now contains provisions for mutual administrative assistance in the collection (recovery) of tax claims in the area of VAT. The number of requests and thus the administrative burden for the states is limited by a minimum amount of the claims to be enforced. In addition, the requested state may retain a lump sum for its own expenses. Finally, it was agreed that the contracting parties will examine the possibilities of mutual administrative assistance in the collection of other tax claims within a period of four years. The protocol of amendment leaves the outcome of this examination open.
The consultation on the protocol of amendment will last until February 6, 2026, after which the protocol of amendment will be submitted to the Federal Assembly for approval. The Federal Council intends to provisionally apply the technical changes to the automatic exchange of information in accordance with the OECD standard from January 1, 2026. The new provisions on administrative assistance for the collection of VAT receivables are not affected by this.
The amendment protocol is available here .
The press release on the signing of the protocol of amendment is available here .
The press release on the opening of the consultation can be downloaded here .
