International Tax Review is part of the Delinian Group, Delinian Limited, 4 Bouverie Street, London, EC4Y 8AX, Registered in England & Wales, Company number 00954730
Copyright © Delinian Limited and its affiliated companies 2023

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Switzerland: The impact of currency fluctuations on the CbCR threshold


Raoul Stocker

Jonathan Belet

On November 23 2016, the Federal Council adopted the Federal Act on the International Automatic Exchange of Country-by-Country Reports of Multinationals (the Act) that aims to implement the country-by-country reporting (CbCR) standard in Switzerland as recommended by the OECD as part of the BEPS project. The Council of States passed the Act on March 16 2017 and the National Council will discuss the draft legislation in June 2017. If the Parliament (i.e. the Council of States and the National Council) approve the proposal and a referendum is not held, the Act should enter into force at the end of 2017.

The CbC report will be required in Switzerland for fiscal years commencing on or after January 1 2018, but voluntary filing will be possible for prior years provided the Act is adopted and Switzerland has a system in place that makes it possible to file the CbC report before the end of 2017.

Multinational enterprises (MNEs) with total annual consolidated group revenues of less than CHF 900 million ($893 million) will not have to file a CbC report in Switzerland. This is in line with the OECD's guidance, which provides that the agreed threshold is €750 million or a near amount in domestic currency as of January 2015. MNE groups that comply with this local threshold requirement denominated in a local currency should not be subject to file a CbC report in any other jurisdiction that is using a threshold denominated in a different currency.

While many countries have followed the implementation guidance from the OECD and applied the January 2015 currency exchange rate to determine the equivalent threshold in domestic currency, several jurisdictions, such as Australia, convert the local threshold on the basis of an average exchange rate for the year for which the CbC report has to be filed.

This could give rise to inconsistent global CbC filing requirements for Swiss headquartered MNEs because the Swiss CbCR threshold was set on the basis of the exchange rate as of January 1 2015 and considering that the Swiss franc soared in mid-January 2015, following the decision by the Swiss National Bank to drop the cap on the franc's value against the euro, and has remained at high levels since then. For instance, a MNE group headquartered in Switzerland with a consolidated turnover of CHF 850 million will be exempt from filing according to the Swiss legislation. However, if the group has an affiliate located in Australia, it will nevertheless be required to file a CbC report as its global turnover is above the Australian threshold of A$1 billion ($737 million) converted in CHF (about CHF 762 million according to the average AUD/CHF exchange rate for 2016).

In light of the above, we recommend Swiss headquartered taxpayers to give due consideration to monetary thresholds and applicable currency exchange rates in the countries where they operate in order to assess the requirement to file a CbC report.

Raoul Stocker ( and Jonathan Belet (


Tel: +41 58 279 6271 and +41 58 279 8430


more across site & bottom lb ros

More from across our site

PwC publishes detailed accounts of its behaviour in the tax scandal in Australia, while another tax trial looms for pop star Shakira.
The winners of the ITR Europe, Middle East, and Africa Tax Awards 2023 have been announced!
The winners of the ITR Asia-Pacific Tax Awards 2023 have been announced!
Mauro Faggion appeared cautiously optimistic as the European Commission waits to see whether all 27 member states will accept its proposal.
The global minimum rate also won’t entirely stop a race to the bottom, according to a tax director speaking at an ITR conference in London.
The country’s tax authorities are not interested in seeing transfer pricing studies any more, it was claimed at an ITR industry conference in London.
The controversial measure is being watered down after criticism from the European Central Bank.
More than 600 such requests were made in 2022, while HMRC has also bolstered its fraud service, it has been revealed.
The General Court reverses its position taken four years ago, while the UN discusses tax policy in New York.
Discussion on amount B under the first part of the OECD's two-pronged approach to international tax reform is far from over, if the latest consultation is anything go by.