Spontaneous Exchange of Rulings – Practical Implications

Switzerland will introduce the international spontaneous exchange of information in tax matters into domestic legislation on the basis of the signed Convention on Mutual Administrative Assistance in Tax Matters (the MAC). This additional kind of exchange of information will be implemented by way of a revision of the Federal Act on International Administrative Assistance in Tax Matters, which should come into force on 1 January 2017. The Federal Council has published the draft of the revised Ordinance on International Administrative Assistance in Tax Matters, which contains detailed provisions on how the spontaneous exchange of information will be implemented, and is currently finalising the ordinance based on the comments received during the consultation phase.