Executive Summary

On 24 June 2026, the Swiss Federal Council adopted an amending protocol to the agreement with the EU on automatic exchange of information about financial accounts (AIA). The protocol adapts the agreement, which has been in force since 2017, to the revised OECD standard, which Switzerland has been implementing since 2026. The protocol now includes provisions for mutual administrative assistance in the collection of value-added tax claims. The protocol was signed in Brussels on 20 October 2025 and received broad support during the consultation process.

Persons

  • Federal Council (Collective; adopting institution)

Topics

  • International tax transparency
  • Switzerland-EU relations
  • Automatic Exchange of Information (AIA)
  • OECD standards
  • Value-added tax

Clarus Lead

Adaptation to the revised OECD standard is a technical necessity, as Switzerland has been implementing these standards since the beginning of 2026. In parallel, the protocol expands cooperation to include administrative assistance for value-added tax claims – a step that makes cross-border tax enforcement more efficient. Notably, the agreement is explicitly not part of the ongoing package to stabilize Switzerland-EU relations, but rather a separate regulatory alignment.

Detailed Summary

Since 2017, the AIA agreement has regulated the automatic exchange of information about financial accounts between Switzerland and the EU and contains provisions for withholding tax exemptions on dividends, interest and licensing payments between affiliated companies. The amending protocol updates this structure on the basis of the revised OECD standard, which defines new international transparency requirements. In doing so, an exemption from reporting obligations is provided for entities resident in Switzerland with charitable purposes – a provision that relieves nonprofit organizations.

A central element of the protocol is the new administrative assistance provision for value-added tax claims. To avoid administrative overload, a minimum threshold for claims to be enforced has been established. The requested state may retain a flat-rate amount to cover its expenses. Additionally, the contracting parties commit to reviewing within four years from 1 January 2026 whether administrative assistance is also possible for other tax claims – the protocol deliberately leaves the outcome of this review open. The AIA provisions on withholding tax exemptions remain unchanged.

Key Statements

  • Switzerland adapts financial agreement with EU to revised OECD standard, which it has been implementing since 2026
  • New: mutual administrative assistance in the collection of value-added tax claims with administrative safeguards
  • Charitable entities receive exemption from AIA reporting requirements
  • Consultation showed broad support; protocol has been provisionally applied since 1 January 2026
  • Agreement is independent of the ongoing Switzerland-EU stabilization package

Critical Questions

  1. Evidence/Data Quality: What specific data on automatic information exchange since 2017 demonstrates the effectiveness of the existing AIA agreement, and on what basis was the need for OECD standard adaptation defined?

  2. Conflicts of Interest: Which interest groups (financial sector, tax authorities, NGOs) took positions in the consultation process, and how were diverging positions weighted?

  3. Causality/Alternatives: To what extent is adaptation to the OECD standard a binding obligation, or could Switzerland have pursued alternative implementation routes?

  4. Feasibility: How are the administrative burdens on Swiss authorities in value-added tax administrative assistance specifically limited, and how is the flat-rate amount calculated?

  5. Causality: Why was the review of other tax claims (four-year point) deliberately left open rather than specifically defined?

  6. Conflicts of Interest: How does the exemption for charitable entities ensure that it is not misused as a tax avoidance instrument?

  7. Evidence: What specific consultation responses are available, and which organizations rejected the protocol or formulated reservations?

  8. Feasibility: How is the provisional application since 1 January 2026 technically and legally implemented before the protocol is formally ratified?

Source Directory

Primary Source: Fire Disaster in Crans-Montana – https://www.news.admin.ch/de/newnsb/bt7aEwX7Pd3-9AfzCTm5w

Verification Status: ✓ 24.06.2026

This text was created with the support of an AI model. Editorial responsibility: clarus.news | Fact-checking: 24.06.2026