The case

The cantons have had record numbers of voluntary disclosures: If these figures were extrapolated to the whole of Switzerland, they would total at an estimated 35,000 voluntary disclosures for 2017 – two to three times as many as in the previous year and more than four times as many in 2015, though 2017 probably included more smaller cases.

According to the Swiss Tax Authority the cantons do not plan to automatically compare the data for the AEoI with the information on the tax returns. However, it has been reported that in some cases software will be used that allows the cantonal authorities to check if the files of the tax payers contain hints whether data for the AEoI are included. The period for the non-punishable voluntary disclosure ended in September 2017.

Source: NZZ-E-Paper 10 January 2018

The commentary

2018 is also an important year for the tax transparency of companies. This means that for the first time about 250 multinational companies domiciled in Switzerland will have to provide country-specific information about turnovers, profits, profits tax as well as number of employees to countries where parts of the companies subject to taxation. In addition to this there will be international reporting duties of “rulings” that are still in power at the beginning of 2018.

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