OECD BEPS – The Swiss Position

In line with its historical inclination to favour multilateral initiatives over isolated unilateral activism, Switzerland has committed to adopt the measures defined as 'minimum standard' contained in BEPS Actions 5, 6, 13 and 14, trusting that these widely recognised measures will establish a fair and equal base in the tax regulation landscape among the OECD and G20 members and beyond.

In this context, it may be surprising for many to learn that a number of the measures proclaimed as minimum standard are already part of Switzerland's policy for negotiating double taxation agreements (DTAs) – for example the dispute resolution measures in BEPS Action 14, or the so-called principal purpose test in BEPS Action 6 which widely corresponds to Switzerland's existing general anti-avoidance rule. As to the rest of the measures which are part of the minimum standard, certain were implemented in 2017 and the rest will be completed by Switzerland over the next few years. The