Exchange of diplomatic notes with the Swiss Confederation concerning the automatic exchange of information under the Convention on Mutual Administrative Assistance in Tax Matters

December 9, 2016
Japanese

  1. 1. On December 8, the Government of Japan and the Swiss Federal Council exchanged diplomatic notes (English (PDF)Open a New Window / Japanese (PDF)Open a New Window) concerning the automatic exchange of information under the Convention on Mutual Administrative Assistance in Tax Matters in Berne, Swiss Confederation.

    2. This exchange of diplomatic notes is intended to ensure that Japan and the Swiss Confederation 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 on the basis of the Convention and, as is already confirmed by the Joint Statement (PDF)Open a New Window between the two Governments signed in January, 2016.

    3. This agreement between the two Governments by the exchange of diplomatic notes will enter into force from the date of entry into force of the Convention in respect of the Swiss Confederation.

    4. It is expected that this exchange of diplomatic notes will ensure the smooth and effective implementation of automatic exchange of information between Japan and the Swiss Confederation and will contribute to the prevention of international tax evasion and tax abuse.

    (Reference 1)
    At the G20 Finance Ministers and Central Bank Governors meeting (Cairns, Australia, September 2014) (PDF)Open a New Window 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 G20 countries are 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 the Swiss Confederation, the Convention will enter into force on 1 January 2017. Without this exchange of diplomatic 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.

    (References 3)
    The agreement between the two Governments by the exchange of diplomatic notes will enter into force on 1 January 2017 as the Convention will enter into force in respect of the Swiss Confederation on that date.