On Monday, 20 October 2025, a significant development in international tax compliance took place as Switzerland and the European Union (EU) signed the Amending Protocol to the Agreement on the automatic exchange of financial account information. The signing ceremony took place in Brussels, marking a momentous step towards improved cooperation and transparency in the realm of taxation.
The AEOI Agreement, which has been in effect since 2017, facilitates the automatic exchange of information between Switzerland and the EU. It also includes provisions for withholding tax exemption for payments of dividends, interest, and royalties between related entities. The Amending Protocol serves to align the Agreement with the amended OECD standard, which Switzerland will implement from 2026 onwards. This update does not result in any significant changes, and the Protocol also includes a provision for exempting Swiss-based Qualified Non-Profit Entities from the reporting requirement.
One of the key additions in the Amending Protocol is the inclusion of provisions for mutual administrative assistance in the recovery of VAT-related taxes. This move aims to reduce the administrative burden on jurisdictions by limiting the number of requests and allowing the requested jurisdiction to retain a lump sum to cover its expenses. Additionally, the Protocol also provides for a review of the potential for mutual assistance in recovering other tax claims within a four-year period.
It is worth noting that the other provisions of the existing AEOI Agreement, such as the withholding tax exemption for related entities, remain unchanged and in effect. Before the Amending Protocol is submitted to Parliament for approval, a public consultation will be conducted to gather feedback from relevant stakeholders.
The Amendment of the AEOI Agreement is a direct result of the revised OECD Standard and is not a part of the package approach to stabilize and further develop the bilateral path between Switzerland and the EU. This negotiation was completely separate from the Switzerland-EU package and was solely focused on aligning the AEOI Agreement with the revised standard.
For any inquiries regarding this development, please contact the State Secretariat for International Finance (SIF) Communications at +41 58 462 46 16 or via email at info@sif.admin.ch.
Derick is an experienced reporter having held multiple senior roles for large publishers across Europe. Specialist subjects include small business and financial emerging markets.