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The Swiss Federal Council has approved plans to revise the Tax Administrative Assistance Ordinance (TAAO), to provide for the spontaneous exchange of information.
The amended TAAO will enter into force on January 1, 2017. The first spontaneous exchanges of information will take place from January 1, 2018, and will apply for tax periods starting from that date.
The ordinance outlines the procedures for and the information to be disclosed to foreign tax authorities, along with the deadlines for the spontaneous exchange of information. It also provides for the spontaneous exchange of information on advance tax rulings, defines which categories will be subject to its provisions, and establishes which countries will receive the information.
The Swiss Federal Council said these provisions are compatible with the OECD's base erosion and profit shifting (BEPS) project, and are based on the OECD/Council of Europe Convention on Mutual Administrative Assistance in Tax Matters and Switzerland's revised Tax Administrative Act. The spontaneous exchange of information will be limited to states that have signed the Convention.
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