EU: Amending protocol with Switzerland to strengthen tax cooperation

The EU signed an amending protocol to strengthen the existing tax cooperation agreement with Switzerland.

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October 20, 2025

The European Union (EU) today signed an amending protocol to strengthen the existing tax cooperation agreement with Switzerland.

According to the release, the protocol aligns the agreement with recent EU and international standards by expanding automatic exchanges of financial account information and establishing a new framework for cooperation on the recovery of value added tax (VAT) claims. 

Background

Between 2015 and 2016, the EU signed agreements with Andorra, Liechtenstein, Monaco, San Marino and Switzerland which provides for the reciprocal automatic exchange of information on financial accounts. The agreements reflect the OECD's common reporting standard (CRS), which the EU implemented through the Directive on Administrative Cooperation (DAC). In 2022, updates to the CRS necessitated the revision of these agreements. 

In May 2024, the Council mandated the Commission to start negotiations with the five countries, and on October 10, 2025, the Council unanimously approved the proposals to authorise the Commission to sign the amending protocols (on behalf of the EU). 

The amendments signed with Switzerland follow similar protocols with Andorra, Liechtenstein, Monaco, and San Marino. These protocols are expected to become effective on January 1, 2026, following the completion of the respective ratification procedures. The amendments with Switzerland related to the CRS updates are expected to apply provisionally from January 1, 2026, with the new provisions on tax recovery taking effect from the first day of January of the first year after the protocol's entry into force.

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