The Ordinance on Country-by-Country Reporting (CbCR-Ordinance) in Switzerland is part of the legal framework implemented to comply with the OECD’s Base Erosion and Profit Shifting (BEPS) Action 13. The ordinance, known as ACREO, was introduced on 1 December 2017, and it came into effect for the first time for tax years starting from 1 January 2018. This ordinance is part of the broader framework that includes the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports (ACRE agreement) and the associated law (ACREA).Key points about the CbCR-Ordinance in Switzerland include:

• Implementation Date: The ordinance was introduced on 1 December 2017.
• Applicability: It applies to multinational enterprise groups with a parent company resident in Switzerland and a turnover of more than CHF 900 million.
• Reporting Obligation: Companies must submit the country-by-country report to the Federal Tax Administration (FTA) no later than 12 months after the last day of the reporting period.
• Exchange of Reports: 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 CbCR-Ordinance in Switzerland is designed to enhance tax transparency and help tax authorities assess transfer pricing and profit shifting within multinational groups.