The Swiss federal tax authorities have introduced a new portal for the submission of Country-by-Country Reporting (CbCR) in Switzerland. Together with the introduction of the portal the Swiss tax authorities have published certain updates to the guidance and announced that from 1 February 2021 CbCRs will need to be submitted in the OECD XML-Scheme 2.0.

The Swiss federal tax authorities (SFTA) published two updates to their guidance documents for the filing of the CbCR in Switzerland this summer. The publication on 24 June 2020 introduced the use of the new filing portal, while the update on 31 August 2020 clarifies the use of the new OECD CbCR-XML-Scheme 2.0 from 1 February 2021 on.

New portal

MNEs filing the CbCR in Switzerland will need to register via the official portal

For persons who have received the filing authorisation for previous years, so-called administrators, the reporting entity will receive a letter with an activation code directly. New administrators will receive a request for power of attorney. It will now be possible to register multiple administrators for the same reporting entity.

For first time filers, who need to register the reporting entity within 90 days after the end of the fiscal year, activation of their access to the portal will complete the registration requirement.

Filing will need to be completed within 12 months after the reporting period via upload of the XML-Scheme in the portal, at which point no specific naming convention will need to be respected anymore. Confirmation of validation will also be visible in the portal from now on.

More information can be found on the SFTA site.

Update to XML scheme

The June update only saw a minor update on MessageRefID and DocRefID requirements for MNEs whose fiscal year does not match the calendar year.

The August update announces the introduction of the OECD CbCR-XML-Scheme 2.0 from 1 February 2021 on. For MNEs using Deloitte’s CbCR Filings Essential Plus platform (previously CDX Smart) for the conversion to XML, an automatic update to the new scheme will be available.

For more information or assistance in filing your CbCR, please do not hesitate to contact us.

Key contacts

Salim Damji - Partner, Transfer Pricing 

Salim is a Tax Partner with more than 20 years of experience in transfer pricing and business model optimisation. He has worked in a variety of countries including the UK, Switzerland, and the US.
Salim has worked with a number of multi-national groups, assisting them in their transfer pricing audits, documentation, and planning issues. Salim’s main focus over the past few years has been intellectual property planning, business restructuring, and APAs.
Salim has been continuously named as one of the world’s leading transfer pricing advisors since 2005 in different journals.

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Kayla Eberli – Senior Manager, Transfer Pricing

Kayla is a Senior Manager in the Business Tax team of Deloitte Switzerland. She has over 6 years of experience providing transfer pricing advisory and compliance support to multinational enterprises across a spectrum of industries and manages projects in the field of consulting to global compliance. She also advises on patent box and R&D super-deduction in Switzerland.

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Aleksandra Skiba - Senior Consultant, Transfer Pricing

Aleksandra is a Senior Consultant in the Transfer Pricing department of Deloitte Switzerland. Having previously worked for a boutique consulting company, she has experience in providing advisory and compliance support for Polish enterprises. Aleksandra has been actively involved in projects concerning transfer pricing documentation, transfer pricing due diligence, IP valuation, Country-by Country Reporting and value chain analysis.

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Remo Artho - Consultant, Transfer Pricing

Remo is a Consultant in the Business Tax team of Deloitte Switzerland with over 2 years of experience. He is involved in various transfer pricing projects with a focus on transfer pricing documentation, benchmarking studies and value chain analyses.

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