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Here you will find everything you need to know about Country-by-Country Reporting (CbCR) between OECD countries. CbCR is the automatic exchange of country-specific reports by multinational companies. This includes the worldwide distribution of turnover, taxes, key figures by country and information on all legal entities of a multinational group. This enables tax administrations to assess transfer pricing and profit shifting.
Questions & answers about 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.
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.
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.
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).
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.
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.
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.
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).
No, reporting companies must create the CbC report in XML format in accordance with the technical manual and submit it via the portal.
The technical guide is online on our website. In case these indications do not provide an answer to your questions, you can send an email to firstname.lastname@example.org.
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 email@example.com.
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 firstname.lastname@example.org. 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 email@example.com so that the group can be activated again on the portal.
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 form (German)
Federal Tax Administration FTA
Main Division for Federal Direct Tax, Anticipatory Tax and Stamp Duty
Team AIA / CbCR
Last modification 05.12.2022