Country-by-Country Reporting CbCR

Here you will find everything you need to know about Country-by-Country Reporting (CbCR): laws and ordinances, CbCR registration and CbCR data transmission.

As English is not one of Switzerland's official languages, only the most important information concerning the Administration is translated into English. This translation is provided for information purposes only and has no legal force. Please refer to the German, French or Italian original version.

Questions and answers about Country-by-Country Reporting CbCR

• Which groups are subject to the CbCR?

  Multinational enterprise groups with a parent company resident in Switzerland and a turnover of more than CHF 900 million are required to file a country-by-country report with the FTA. The FTA automatically forwards the country-by-country reports to the tax authorities of the partner countries and makes them available to the tax authorities of the cantons in which entities belonging to the same multinational enterprise group are resident.

• Which countries participate in the CbCR?

  The list of partner countries with which Switzerland has signed an agreement to apply the CbCR is published on the State secretariat for International Finance SIF website. The FTA is responsible for the implementation of the CbCR.

• Who should register and when? On what date must the CbCR be submitted to the FTA?

  The legal framework for the implementation of the exchange of country-by-country reports came into force on 1 December 2017. The obligation to provide a country-by-country report is in place for the first time for tax years starting from 1 January 2018. The first regular exchange took place in 2020. Reporting entities are required to report spontaneously to the FTA. The reporting obligation must be fulfilled no later than 90 days after the end of the reportable tax period. The country-by-country report must be submitted to the FTA no later than 12 months after the last day of the reporting period.

• Our company is part of a group. Do we have to provide the FTA with information on the constituent entity (reporting entity) required to send the country-by-country report (notification obligation)?

  No, in Switzerland there is no notification obligation, which means that subsidiaries of foreign groups based in Switzerland do not have to inform the FTA which company of the group will submit the country-by-country report. The reporting obligation must be distinguished from the legal entity that prepares the report according to article 10, paragraph 1 of the CbC Act (the obligation to declare is normally the task of the parent company of the group).

• Our company has already submitted a CbC report last year. Do we have to register the company on the portal every year?

  No, it is not necessary to register every year. Once the company has registered on the portal and used the invitation code, the company can submit the CbC report online for the following years without prior registration.

• We are a service provider and would like to submit the CbC report for one of our clients. Is this possible?

  Yes, groups can appoint the administrator for the processing of CbCR matters on the portal themselves. In this case, the invitation code generated on the portal during registration must be transmitted to the service provider. By entering the code on the portal, the responsible person at the service provider will obtain administrator rights and will be able to submit the CbC report for the legal entity. For more information on registration and transmission of data, please visit our website.

• We are a service provider but we have no administrator rights in the portal, we only prepare the report for our clients. Is it possible to have access to the portal to test the registration process and the reports for our clients?

  No, service providers do not receive access to the portal from the FTA. Registration as a responsible legal entity and the submission of reports for testing purposes are only possible for companies subject to the CbCR obligation.

• Can we also submit the CbC report by e-mail, on paper or in Excel format?

  No, the CbC report can only be submitted online via the portal and must meet the requirements of the technical manual (submission only possible in XML format).

• Does the FTA provide companies with a tool to convert Excel data into XML, for instance?

  No, reporting companies must create the CbC report in XML format in accordance with the technical manual and submit it via the portal.

• We have questions about XML. Whom should we contact?

  The technical guide (German version) is online on our website. In case these indications do not provide an answer to your questions, you can send an email to [e-mail].

• We have questions regarding the content of the CbC report. Whom can we contact?

  In addition to the legal bases, the OECD guidelines and the "Common errors made by multinational enterprises s in preparing CbC reports" (also published by the OECD) may be of assistance. Both documents are linked on our website. Alternatively, you can write an email to [e-mail].

• Our group has submitted CbC reports every yearuntil today, but it no longer passes the threshold. Do we have to inform the FTA?

  Yes. In this case, the group must be deregistered; otherwise the recall process will be initiated after the submission deadline has passed. For deregistration, we need evidence (consolidated annual accounts) that the turnover threshold has not been reached. The application for deregistration (including supporting documents) can be sent to [e-mail]. The FTA will issue a written confirmation of deregistration. If the company reaches or exceeds the turnover threshold again at a later date, a new CbC report must be submitted. In this case, the AIA team must be informed via [e-mail] so that the group can be activated again on the portal.

• We submitted a CbC report, but later discovered errors in the report. What can we do?

  If the report accepted on the portal contains errors, a correction of the report should be sent immediately according to the guidelines indicated in the technical guide.

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Contact

Contact form (German)

Federal Tax Administration FTA
Main Division for Federal Direct Tax, Anticipatory Tax and Stamp Duty
Team AIA / CbCR
Eigerstrasse 65
3003 Berne