In all, the FTA has transmitted a first batch of 82 reports to a total of 41 states, including France, Germany, the United Kingdom, the Netherlands and Russia. Certain reports are exchanged with several partner states. Advance tax rulings which were still effective on 1 January 2018 are concerned.
Switzerland has ratified the OECD/Council of Europe Multilateral Administrative Assistance Convention and, within the framework of the BEPS project, undertaken to spontaneously forward reports on certain advance tax rulings to partner states (Article 9 of the Tax Administrative Assistance Ordinance). That means that each country must itself identify the advance tax rulings and the recipient states, and transmit the information to the partner states (Articles 10 and 13 of the Tax Administrative Assistance Ordinance). The partner states to the convention have agreed to spontaneously exchange the content of advance tax rulings in the form of a template. The advance tax rulings themselves are not exchanged.
Ordinarily, advance tax rulings are issued by the cantonal tax administrations in Switzerland. The cantons must forward these to the FTA. The FTA carries out the administrative assistance procedure and transmits ruling reports to the partner states within the framework of the spontaneous exchange of information.
Address for enquiries
Patrick Teuscher, Head of Communications
Swiss Federal Tax Administration FTA
Tel. +41 58 464 90 00, email@example.com
The Federal Tax Administration