The automatic exchange of information (AEOI) between Switzerland and the EU has been implemented by means of the AEOI Agreement since 2017. The Agreement also contains provisions on withholding tax exemption for payments of dividends, interest and royalties between related entities. The Amending Protocol adapts the AEOI Agreement to the revised OECD standard, which Switzerland will implement from 2026 onwards. There are no material differences with respect to this. The Protocol also provides for an exemption from the reporting requirement for Swiss-based Qualified Non-Profit Entities. The Amending Protocol was signed in Brussels on 20 October 2025.
The Amending Protocol now contains provisions for mutual administrative assistance for the recovery of tax claims relating to VAT. The number of requests, and thus the administrative burden for jurisdictions, is limited by imposing a minimum amount for the claims to be recovered. Furthermore, the requested jurisdiction may retain a lump sum to cover its expenses. Finally, it has been agreed that the contracting parties will, within a period of four years, explore the potential for mutual administrative assistance in recovering other tax claims. The outcome of this review has been left open in the Amending Protocol.
The other provisions of the existing AEOI Agreement, particularly those on the withholding tax exemption for related entities, are not affected by the Amending Protocol and remain in place.
The amendment of the AEOI Agreement between Switzerland and the EU is a consequence of the revised OECD standard and is not part of the package approach to stabilise and further develop the bilateral path. The negotiations to amend the AEOI Agreement were thus unrelated to the Switzerland-EU package.
The consultation will run until 6 February 2026, and the Amending Protocol will subsequently be submitted to Parliament for approval.
The Federal Council intends to provisionally apply the technical changes to the automatic exchange of information in accordance with the OECD standard from 1 January 2026. The new provisions on administrative assistance for the recovery of VAT claims are not affected by this.
Appendices
Address for enquiries:
State Secretariat for International Finance SIF Communications +41 58 462 46 16 info@sif.admin.ch
