Meeting on 22 October, the Federal Council launched a public consultation on an amending protocol to Switzerland’s agreement with the European Union on the Automatic Exchange of Information (AEOI). The revision aligns Swiss practice with the OECD’s updated Common Reporting Standard and introduces mutual assistance for recovering cross-border VAT claims.
While the proposal is primarily fiscal, it has tangible mobility implications. Tens of thousands of Swiss citizens on overseas assignments retain bank accounts at home, and foreign executives seconded to Switzerland often maintain investment portfolios abroad. Harmonising data fields and reporting timelines should reduce double-filing headaches and cut the risk of unexpected tax bills that can derail assignments.
Tax advisers note that the protocol will also exempt certain dividend, royalty and interest payments between related entities from withholding tax, provided both parties share information under the new standard. Multinationals headquartered in Switzerland stand to save administrative costs when relocating senior staff across EU borders.
If approved by Parliament in 2026, the revised agreement would take effect for the 2027 reporting year. The Federal Council is collecting stakeholder feedback until 31 January 2026, after which it will finalise a message to legislators. Mobility managers are encouraged to review the draft and flag any residency-status anomalies that could affect internationally mobile employees.
Experts caution that greater data transparency heightens the importance of accurate home-and host-country payroll reporting. Companies should therefore audit shadow-payroll setups before the new rules bite to avoid compliance penalties both in Switzerland and the EU.
While the proposal is primarily fiscal, it has tangible mobility implications. Tens of thousands of Swiss citizens on overseas assignments retain bank accounts at home, and foreign executives seconded to Switzerland often maintain investment portfolios abroad. Harmonising data fields and reporting timelines should reduce double-filing headaches and cut the risk of unexpected tax bills that can derail assignments.
Tax advisers note that the protocol will also exempt certain dividend, royalty and interest payments between related entities from withholding tax, provided both parties share information under the new standard. Multinationals headquartered in Switzerland stand to save administrative costs when relocating senior staff across EU borders.
If approved by Parliament in 2026, the revised agreement would take effect for the 2027 reporting year. The Federal Council is collecting stakeholder feedback until 31 January 2026, after which it will finalise a message to legislators. Mobility managers are encouraged to review the draft and flag any residency-status anomalies that could affect internationally mobile employees.
Experts caution that greater data transparency heightens the importance of accurate home-and host-country payroll reporting. Companies should therefore audit shadow-payroll setups before the new rules bite to avoid compliance penalties both in Switzerland and the EU.
