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[Provisional translation]

December 9, 2016
The Ministry of Finance

Notes exchanged with Switzerland concerning the automatic exchange of information under the Convention on Mutual Administrative Assistance in Tax Matters

1.  On December 8(Thu), the Government of Japan and the Swiss Federal Council exchanged the Notes concerning the automatic exchange of information under the Convention on Mutual Administrative Assistance in Tax Matters in Bern.

2.  On the basis of the Convention, this Exchange of Notes is intended to ensure that Japan and Switzerland will be able to commence the automatic exchange of financial account information related to taxable periods or charges to tax beginning on or after 1 January 2017 from 2018 in accordance with the Common Reporting Standard established by the OECD, as is already confirmed by the Joint Statement between the two Governments signed last January.

3.  This agreement between the two Governments by the Exchanged Notes will enter into force from the date of entry into force of the Convention in respect of Switzerland.

4.  This Exchange of Notes ensures the smooth and effective implementation of automatic exchange of information between Japan and Switzerland, and is expected to contribute to the prevention of international tax evasion and tax abuse between the two countries.


【Reference 1】
At the G20 Finance Ministers and Central Bank Governors meeting (Cairns, Australia, September 2014) and the G20 summit meeting (Brisbane, Australia, November 2014), the global Common Reporting Standard for the automatic exchange of tax information (AEOI), established by the OECD, was endorsed, and countries are called on to begin to exchange information automatically by 2017 or end-2018, subject to completing necessary legislative procedures, which the Government of Japan has already completed by FY 2015 Japan Tax Reform.

【Reference 2】Convention on Mutual Administrative Assistance in Tax Matters

  • The Convention is a multilateral treaty for the implementation of various administrative assistances in tax matters including the exchange of information among the tax authorities.
  • In respect of Japan, the Convention entered into force on 1 October 2013.
  • In respect of Switzerland, the Convention will enter into force on 1 January 2017. Without the Exchanged Notes, the Convention would have effect for the automatic exchange of information related to taxable periods or charges to tax beginning on or after 1 January 2018 in accordance with the relevant articles of the Convention.

【Reference 3】
The agreement between the two Governments by the Exchanged Notes will enter into force on 1 January 2017 because the Convention will enter into force in respect of Switzerland on that date.

【Reference 4】
Exchanged Notes between the Government of Japan and the Swiss Federal Council concerning the automatic exchange of information under Article 6 of the Convention on Mutual Administrative Assistance in Tax Matters(JapaneseEnglish (51KB/66KB)PDF)

Contact

Ministry of Finance : Tel 03(3581)4111

 International Tax Policy Division, Tax Bureau (ext. 5006)