Spontaneous exchange

Spontaneous information exchange is the international transmission of information related to tax matters by the initiative of one of the states participating in the information exchange on the basis of Convention on Mutual Administrative Assistance in Tax Matters. In this context, spontaneous means that no request was submitted before. The information is thus exchanged if the transmitting country suspects that information available might be of interest to another country, mainly in cases where: (a) there are grounds for supposing that there may be a loss of tax in the other country due to deliberate actions of the involved persons on the territory of the transmitting country; (b) a taxable person received a reduction or exemption from tax in the transmitting country; (c) the transmitting country has information that might be helpful to another country in verifying the amount of tax liabilities of its residents. 

In Switzerland the spontaneous exchange of information is mostly used in the area of advance tax rulings (which potentially bear a risk of base erosion and profit shifting-BEPS). Switzerland has for the first time spontaneously exchanged information on tax rulings in 2019 on the basis of the information valid for 2018. 

MP Part will be able to give a hand in any matters related to spontaneous information exchange. Please contact us if you have any interest or request related to this specific type of activity.