Automatic exchange of information between Switzerland and EU: Federal Council adopts dispatch on Protocol of Amendment
Bern, 24.06.2026 — During its meeting on 24 June 2026, the Federal Council adopted the dispatch on the Protocol of Amendment to the Agreement between Switzerland and the European Union (EU) on the automatic exchange of financial account information to improve international tax compliance. The Agreement will be aligned with the revised OECD standard and also contains new provisions on administrative assistance for the recovery of VAT claims. The overwhelming majority of consultation participants agree with the proposal.
The automatic exchange of financial account 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 exemptions for payments of dividends, interest and royalties between related entities. Through the Protocol of Amendment, the AEOI Agreement will be aligned with the revised OECD standard, which Switzerland has implemented since 2026. The Protocol also provides for an exemption from the reporting requirement for Swiss-based qualified non-profit entities. The Protocol of Amendment was signed in Brussels on 20 October 2025.
The Protocol of Amendment now contains provisions on mutual administrative assistance with regard to the recovery of VAT-related tax claims. 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 starting on 1 January 2026, explore the potential for mutual administrative assistance in recovering other tax claims. The outcome of this review has been left open in the Protocol of Amendment.
The other provisions of the existing AEOI Agreement, particularly those on the withholding tax exemption for related entities, are not affected by the Protocol of Amendment and continue to apply unchanged.
The consultation has shown that the Protocol of Amendment on the AEOI Agreement meets with broad support. The provisions in the Protocol regarding the automatic exchange of information in line with the OECD standard have applied provisionally since 1 January 2026. The new provisions on administrative assistance for the recovery of VAT claims are not affected by this.
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 to stabilise and further develop relations between Switzerland and the EU.