On Monday, October 20, 2025, a significant agreement was signed in Brussels between Switzerland and the European Union (EU). The two parties came together to sign the Amending Protocol to the Agreement on the automatic exchange of financial account information, with the goal of improving international tax compliance. This historic moment marks a significant step towards greater transparency and cooperation in the realm of financial transactions.
The automatic exchange of information (AEOI) between Switzerland and the EU has been in effect since 2017, thanks to the AEOI Agreement. This agreement also includes provisions for withholding tax exemption for payments of dividends, interest, and royalties between related entities. With the Amending Protocol, the AEOI agreement will now be aligned with the amended OECD standard, and new provisions will be added to facilitate administrative assistance for the collection of VAT claims.
One of the key changes brought about by the Amending Protocol is the adaptation of the AEOI agreement to the revised OECD Standard, which Switzerland will implement starting in 2026. While there are no significant differences in this regard, the Protocol also includes an exemption from the reporting requirement for Swiss-based Qualified Non-Profit Entities.
In addition to the changes related to the OECD Standard, the Amending Protocol also includes provisions for mutual administrative assistance in the recovery of tax relating to VAT. To minimize the administrative burden for jurisdictions, a minimum amount of the claims to be recovered has been established, and the requested jurisdiction may retain a lump sum to cover its expenses. Furthermore, the contracting parties have agreed to explore the potential for mutual assistance in recovering other tax claims within a period of four years, with the outcome of this review being left open in the Amending Protocol.
It is important to note that the other provisions of the existing AEOI Agreement, particularly those regarding withholding tax exemption for related entities, remain unaffected by the Amending Protocol and will remain in place.
Before the Amending Protocol is submitted to Parliament for approval, a public consultation will be conducted to gather input and feedback from stakeholders.
It is worth mentioning that the Amendment of the AEOI agreement is a direct result of the revised OECD Standard and is not part of the package approach to stabilize and further develop the bilateral path. The negotiations to amend the AEOI Agreement were independent of the Switzerland-EU package.
For any inquiries related to this significant development, please contact the State Secretariat for International Finance (SIF) Communications at +41 58 462 46 16 or info@sif.admin.ch.
