Switzerland. Total MAP Caseload. Average time needed to close MAP cases (in months)

Transcription

1 Switzerland Start inventory on..27 Total MAP Caseload Cases started Cases closed End inventory on Cases started before January 26 Cases started as from January start inventory Cases started Cases closed 27 end inventory start inventory Cases started Cases closed 27 end inventory Cases started before January 26 Cases started as from January 26 Average time needed to close MAP cases (in months) Cases started before January 26 Average time Note: the average time taken to close MAP cases that started before January 26 was computed by applying the following rules: (i) start date: the date of filing of the MAP request; and (ii) end date: the earliest of the following dates: (a) the date when the taxpayer is informed of the outcome of the MAP, (b) the date of the closing letter which is drafted upon taxpayer's approval of the reached, or (c) the date when the Swiss Competent Authority formally closed the case. Cases started as from January 26 Start to End Receipt to Start Start to Milestone Milestone to End Note: the average times to close MAP cases that started as from January 26 were computed according to the MAP statistics reporting framework available at Switzerland - 27 MAP Statistics Page /9

2 Overview of MAP partners (only for cases started as from January 26) Note: the MAP cases started before January 26 and closed in 27 are not shown in these graphs Austria Canada France Germany Italy Korea United States Treaty Partners (de minimis rule Cases in 27 start inventory + cases started in 27 Cases closed in 27 applies) Treaty Partners (Others) Austria Belgium France Germany Luxembourg Netherlands Treaty Partners (de minimis rule applies) Cases in 27 start inventory + cases started in 27 Cases closed in Treaty Partners (Others) The label "Treaty Partners (de minimis rule applies)" applies to treaty partners with which the number of cases in start inventory plus the number of cases started is at least 5. The relevant MAP statistics are aggregated under this category. The label "Treaty Partners (Others)" applies to treaty partners that are not reporting MAP statistics for the reporting period. The relevant MAP statistics are aggregated under this category. Switzerland - 27 MAP Statistics Page 2/9

3 MAP Outcomes % % 2% 4% 4% denied MAP access 9% objection is not justified.5% withdrawn by taxpayer unilateral relief granted resolved via domestic remedy fully double taxation / fully resolving that there is no 79% no including to disagree Cases closed by outcome denied MAP access objection is not justified withdrawn by taxpayer unilateral relief granted resolved via domestic remedy fully double taxation / fully resolving partially double taxation / partially resolving that there is no no including to disagree any other outcome Total (all) Cases started before January Cases started as from January (all) Cases started before January Cases started as from January All cases Switzerland - 27 MAP Statistics Page 3/9

4 Annex A MAP Statistics Reporting for the 27 Reporting Period ( January 27 to 3 December 27) for Pre-26 Cases Switzerla nd category of cases no. of pre-26 cases in MAP inventory on January 27 denied MAP access objection is not justified withdrawn by taxpayer number of pre-26 cases closed during the reporting period by outcome: unilateral relief granted resolved via domestic remedy fully double taxation / fully resolving with partially double taxation / partially resolving with that there is no with no including to disagree any other outcome no. of pre- 26 cases remaining in on MAP inventory on 3 December 27 average time taken (in months) for closing pre- 26 cases during the reporting period Row Column Column 2 Column 3 Column 4 Column 5 Column 6 Column 7 Column 8 Column 9 Column Column Column 2 Column 3 Column 4 Attribution/ Allocation Row 2 Others Row 3 Total ) In general, Switzerland uses the same methods to (i) classify the MAP "pre- 26"-cases and (ii) to count these "pre- 26"-cases as for the "post-25"-cases (according to MAP Statistics Reporting Framework.) 2) In general, information reported for 27 MAP statistics: (i) start date: the date of filing of the MAP request; and (ii) end date: the earliest of the following dates: (a) the date when the taxpayer is informed of the outcome of the MAP, (b) the date of the closing letter which is drafted upon taxpayer's approval of the reached, or (c) the date when the Swiss Competent Authority formally closed the case. 3) Other and attribution/allocation new cases: The competent authorities of other countries informed Switzerland about these new cases ( TP and 8 other cases) only in the year 27. Switzerland was not able to report them in 26. Switzerland - 27 MAP Statistics Page 4/9

5 MAP Statistics Reporting for the 27 Reporting Period ( January 27 to 3 December 27) for Post-25 Cases Table : Attribution / Allocation MAP Cases number of post-25 cases closed during the reporting period by outcome: Treaty Partner 25 cases in MAP inventory on January cases started during the reporting period denied MAP access objection is not justified withdrawn by taxpayer unilateral relief granted resolved via domestic remedy fully double taxation eliminated / fully resolving partially double taxation / partially resolving taxation not in with that there is no taxation not in with no including to disagree any other outcome 25 cases remaining in MAP inventory on 3 December 27 Column Column 2 Column 3 Column 4 Column 5 Column 6 Column 7 Column 8 Column 9 Column Column Column 2 Column 3 Column 4 Row Austria Canada France 4 4 Germany Italy 7 6 Korea 2 United States 9 8 Row 2 Treaty Partners (de minimis rule applies) Row 3 Treaty Partners (Others) Total Notes The mismatch between 26 end inventory and 27 start inventory can be explained by the reclassification of some cases. Switzerland - 27 MAP Statistics Page 5/9

6 MAP Statistics Reporting for the 27 Reporting Period ( January 27 to 3 December 27) for Post-25 Cases denied MAP access objection is not justified withdrawn by taxpayer unilateral relief granted resolved via domestic remedy fully double taxation / fully resolving partially double taxation / partially resolving taxation not in with that there is no taxation not in with no including to disagree Column Column 2 Column 3 Column 4 Column 5 Column 6 Column 7 Column 8 Column 9 Column Column Column 2 Column 3 Column 4 Row Austria 6 5 Belgium France Germany Luxembourg Netherlands Row 2 Treaty Partners (de minimis rule applies) Row 3 Treaty Partners (Others) Total Treaty Partner 25 cases in MAP inventory on January cases started during the reporting period Table 2: Other MAP Cases The mismatch between 26 end inventory and 27 start inventory can be explained by the requalification of one case, from other case to TP case. number of post-25 cases closed during the reporting period by outcome any other outcome 25 cases remaining in MAP inventory on 3 December 27 Switzerland - 27 MAP Statistics Page 6/9

7 MAP Statistics Reporting for the 27 Reporting Period ( January 27 to 3 December 27) for Post-25 Cases "Start" to "End" Receipt of taxpayer's MAP request to "Start" "Start" to Milestone Milestone to "End" Column Column 2 Column 3 Column 4 Column 5 Row Austria Canada France Germany Italy Korea United States Row 2 Treaty Partners (de minimis rule applies) Row 3 Treaty Partners (Others) Treaty Partner Table : Attribution / Allocation MAP Cases average time taken (in months) for post-25 cases from: Total Average Time Switzerland - 27 MAP Statistics Page 7/9

8 MAP Statistics Reporting for the 27 Reporting Period ( January 27 to 3 December 27) for Post-25 Cases "Start" to "End" Receipt of taxpayer's MAP request to "Start" "Start" to Milestone Milestone to "End" Column Column 2 Column 3 Column 4 Column 5 Row Austria Belgium Germany France Luxembourg Netherlands Row 2 Treaty Partners (de minimis rule applies) Row 3 Treaty Partners (Others) Total Average Time Treaty Partner Table 2: Other MAP Cases average time taken (in months) for post-25 cases from: Switzerland - 27 MAP Statistics Page 8/9

9 MAP Statistics Reporting for the 27 Reporting Period ( January 27 to 3 December 27) for Post-25 Cases "Start" to "End" Receipt of taxpayer's MAP request to "Start" "Start" to Milestone Milestone to "End" Column Column 2 Column 3 Column 4 Row Total Average Time Table 3: All MAP Cases average time taken (in months) for post-25 cases from: Switzerland - 27 MAP Statistics Page 9/9