For the first time, Switzerland’s Federal Tax Administration (FTA) has sent details on advance tax rulings to its partners in the spontaneous exchange of information deal.
The FTA announced on Tuesdayexternal link that it had transmitted a first batch of 82 reports to a total of 41 states, including Britain, France, Germany, the Netherlands and Russia. Some reports were exchanged with several partner countries.
Under the spontaneous exchange of information accord, the tax authorities come forward if they encounter something that may interest another state.
Switzerland, by ratifying the OECD/Council of Europe Multilateral Administrative Assistance Conventionexternal link, agreed to spontaneously forward reports on certain advance tax rulings to partner states within the framework of the OECD’s base erosion and profit shifting (BEPS) projectexternal link.
That means that each country must itself identify the advance tax rulings and the applicable recipient states, and transmit the information. This first batch concerns advance tax rulings which were still effective on January 1, 2018. The advance tax rulings themselves are not exchanged.
Ordinarily, advance tax rulings are issued by Switzerland’s cantonal tax administrations. The cantons must forward these to the FTA, and the FTA carries out the administrative assistance procedure and transmits ruling reports to the partner states.
SDA/ATS, swissinfo.ch, sm