31.05.2024

5'

CRS Reporting Reminder 2024

Swiss financial institutions must report CRS-reportable 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, 2024 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 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 which outlines 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 2023

In addition to account holders resident in jurisdictions that were reportable for tax year 2022, from tax year 2023 on, Swiss financial institutions must also report all account holders resident in countries which have a reciprocal CRS Agreement in force since January 1, 2023. 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 2023 reporting:

Of these states and territories, New Caledonia is declared a "permanent non-reciprocal jurisdiction" and Sint Maarten a “temporary non-reciprocal jurisdiction”. This means that Sint Maarten and New Caledonia will initially provide information on financial accounts to Switzerland but will not receive such information. With respect to Sint Maarten, Reporting Swiss financial institutions must collect the relevant data from the time of activation of the CRS (January 1, 2023) and forward them to the SFTA within the specified period. However, the SFTA will only forward this data to Sint Maarten once it fulfils all the requirements of the CRS regarding confidentiality.

In addition, the Swiss Federal Council suspended the data transmission to Russia. However, we would like to remind that the obligations of Swiss Reporting FIs towards the SFTA remain unaffected by this decision: Notwithstanding the suspension, the Reporting FIs are required to collect and report to the SFTA the financial account data of tax residents in Russia.

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 2023:

Deadline in other relevant jurisdictions

The following jurisdictions are repeatedly amongst the most relevant ones for CRS Reporting, and thus listed with their respective CRS reporting deadlines.