22.06.2021

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CRS Reporting Reminder 2021

Swiss financial institutions must report CRS data to the Swiss Federal Tax Authority (SFTA). To do so, Swiss Reporting FIs must register on the Swiss registration and filing portal.

The reporting FIs must transmit the reportable information to the SFTA by June 30, 2021 the latest. For updates regarding the deadlines for filing the CRS Reporting in other jurisdictions, the respective local guidance should be considered.

Swiss Reporting FIs registered with the SFTA, regardless of whether they maintained reportable accounts in the respective calendar year or not, must submit a reporting file to the SFTA. If the reporting FI did not have any reportable accounts, a nil reporting is required.

The reports must be filed according to the SFTA technical guidance.

Additionally, the SFTA has released a data transmission guide outlining technical specifications on how to transmit data to the FTA.

The data can be filed in three ways:

  1. Upload of encrypted XML-file via SFTA Portal (XML Data Upload)

  2. Manual data entry via SFTA Portal (online form)

  3. Machine-to-machine webservice interface (M2M)

If a FI chooses the third option, the interface must be activated first. The reports cannot be filed in paper form.

Changes in Reportable Jurisdictions for Tax Year 2020

In addition to account holders resident in jurisdictions that were reportable for tax year 2019, from tax year 2020 on, Swiss financial institutions must also report all account holders resident in countries having a reciprocal CRS Agreement in force since January 1, 2020. You can find a list of all countries on the Website of the State Secretariat for International Finance. The following countries are new for the tax year 2020 reporting:

Of these states and territories, Dominica, Ghana, Lebanon, Macao and Samoa are declared as "temporary non-reciprocal jurisdictions". This means that they will initially provide information on financial accounts but will not receive such information until they meet all the requirements of the CRS. Reporting Swiss financial institutions must collect the relevant data from the time of activation of the CRS (January 1, 2020) for these states and territories, and forward them to the SFTA within the specified period, however, the SFTA will only forward this data to the partner states once they fulfil the conditions for a reciprocal data exchange.

Additionally, we would like to emphasize that starting January 1, 2021 the United Kingdom has a reciprocal CRS Agreement with Switzerland in place which means that, notwithstanding Brexit, the automatic exchange of information between UK and Switzerland will continue as usual for the tax year 2020, as well as for subsequent years.

Reportable accounts of jurisdictions with non-reciprocal agreements

Please be reminded that some jurisdictions are declared as "permanent non-reciprocal jurisdictions", i.e. they will supply account information to the partner jurisdictions on a permanent basis, but do not wish to receive such data. A Swiss Financial Institution must therefore not include reportable accounts of clients with a tax residency in the following permanent non-reciprocal jurisdictions for the tax year 2020:

We also note that starting January 1, 2021 Vanuatu changed its status from “permanent non-reciprocal jurisdiction” to “temporary non-reciprocal jurisdiction”. Therefore, account holders resident in Vanuatu will have to be reported for tax year 2021.