1. Tax Transparency and Automatization – The Perspective of the Tax Administration EATLP Congress 2018 Zurich 8 June Christoph Schelling Ambassador, Head of Tax Division State Secretariat for International Finance SIF, Bern

2. Overview Interaction between Tax Authority and Taxpayer
Tax Authority’s access to data & information in the hands of other persons or bodies
Access to taxpayer data & information in the hands of the Tax Authority
Cross-border information exchange and cooperation in tax matters
Conclusion
Tax Transparency and Automatization - The Perspective of the Tax Administration Christoph Schelling, EATLP Congress 2018 Zurich, 8 June 2018

3. (1) Interaction between Tax Authority and Taxpayer
The role of the Tax Authority
Switzerland is a Federal State: Tax authorities operate at the levels of the Confederation & the Cantons and Municipalities
Cooperation Model: Tax Authority and Taxpayer
Taxpayer’s obligation to cooperate
Electronic filing and files
Features underpinning the Cooperation Model:
Withholding tax on capital income
Information provided by or available from third sources
Taxation upon Best Estimate of the Tax Authority
Tax Readjustment & Penalties
Tax Authority’s obligation to assess Taxpayer in respect of and based on the applicable law
Tax Transparency and Automatization - The Perspective of the Tax Administration Christoph Schelling, EATLP Congress 2018 Zurich, 8 June 2018

4. (2) Tax Authority’s access to data & information in the hands of other persons or bodies
Other administrative bodies and courts
Third parties: esp. employers, creditors, fiduciaries and accountants, companies, pension funds
Third parties: Swiss banks
No access by Tax Authority, except for the Federal Tax Administration in cases of «continued evasion of large sums of taxes», with the assent of the Minister of Finance of the Confederation
Access however by criminal prosecution authorites in cases of «tax fraud» (tax fraud meaning evasion by using false or falsified documents)
Tax Transparency and Automatization - The Perspective of the Tax Administration Christoph Schelling, EATLP Congress 2018 Zurich, 8 June 2018

5. (3) Access to taxpayer data & information in the hands of the Tax Authority
Constitutional Rights & Principles
Taxpayer Access to the Tax Authority’s file re. the Taxpayer
Tax Secrecy Principle & exceptions
Information Exchange with other jurisdictions
Data Protection
Freedom of Information
Tax Transparency and Automatization - The Perspective of the Tax Administration Christoph Schelling, EATLP Congress 2018 Zurich, 8 June 2018

6. (4) Cross-border information exchange and cooperation in tax matters
Information Exchange upon Request: OECD standard based on Art. 26 of the Model Convention
Spontaneous Information Exchange: esp. OECD standard re. tax rulings
Automatic Information Exchange: esp. OECD standards re. financial account information & country-by-country reporting for large multinational enterprises
Procedural Rights of persons subject to information exchange: Federal law on administrative assistance in tax matters & Federal law on automatic exchange of information
The Federal Tax Administration acting as Competent Authority under international treaties
Outbound information flows
Inbound information flows
Tax Transparency and Automatization - The Perspective of the Tax Administration Christoph Schelling, EATLP Congress 2018 Zurich, 8 June 2018

7. (5) Conclusion
Tax Transparency and Automatization - The Perspective of the Tax Administration Christoph Schelling, EATLP Congress 2018 Zurich, 8 June 2018