AEOI Ordinance

By Steph2
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In The Matter OfAEOI Ordinance
Exhibit A
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Inserted by No I of the O of 26 Nov. 2025, in force since 1 Jan. 2026 (AS 2025 817).

English is not an official language of the Swiss Confederation. This translation is provided for information purposes only and has no legal force.

Section 1 Relevant Version of the OECD Commentarie

Art. 30a

The version of the OECD commentaries on the Multilateral Model Competent Authority Agreement on the Automatic Exchange of Information in accordance with the Crypto-Asset Reporting Framework and on the Crypto-Asset Reporting Framework (CARF) that is relevant under Article 2b paragraph 2 AEOIA is that of 8 June 2023.

These commentaries may be accessed free of charge at: www.oecd.org > Topics > Taxation > Tax Transparency and International Co-operation > Related Publications > International Standards for Automatic Exchange of Information in Tax Matters: Crypto-Asset Reporting Framework and 2023 Update to the Common Reporting Standard.

Section 2 Relevant Reporting Crypto-Asset Service

Art. 30b

1 Reporting crypto-asset service providers that establish a personal connection with Switzerland pursuant to Article 3 or 50 DFTA are deemed to be resident in Switzerland for tax purposes pursuant to Article 12b paragraph 1 AEOIA. 2 Persons or entities required to file a tax return or a tax information return in Switzerland are subject to a duty to file tax information forms under Article 12b paragraph 1 AEOIA. The following are regarded as a tax return or a tax information return: a. the tax return for direct federal tax; b. the tax return for direct cantonal tax; c. certificates under Article 129 paragraph 1 letter c DFTA; d. certificates pursuant to the cantonal statutory provisions implementing Article 45 paragraph 1 letter c of the Tax Harmonisation Act of 14 December 1990. 3 Reporting crypto-asset service providers are deemed to have a branch office in Switzerland pursuant to Article 12b paragraph 1 AEOIA if they established an economic connection with Switzerland pursuant to Art

Para. 1 — SR 642.11 Para. 2 let. d — SR 642.14

Section 3 Further Details on Reporting Obligations

Art. 30c

Reporting Swiss crypto-asset service providers may, in the event of the death of a person from a reporting state, treat that person’s estate as an estate with its own legal personality until the dissolution of the community of heirs. The estate is deemed to be a reportable person in that state or sovereign territory in which the deceased was last resident for tax purposes.

Section 4 Further Details on Due Diligence Obligat

Art. 30d Establishing a business relationship with a crypto-asset user

1 Cases in which a business relationship with a crypto-asset user is established without the reporting Swiss crypto-asset service providers contributing to or being able to prevent the same are deemed to be exceptions under Article 12f paragraph 3 AEOIA. 2 These exceptions include in particular: a. a change in the crypto-asset user as a consequence of a court or official order; b. the creation of a beneficiary claim against a trust or similar legal entity on the basis of its deed of creation or the foundation deed.

Art. 30e Termination of a business relationship

1 If a business relationship is terminated before expiry of the deadlines in Article 12f paragraphs 1, 3 and 4 AEOIA and if the review of the business relationship by the reporting Swiss crypto-asset service provider has not been completed at the time of termination, the Reporting Swiss crypto-asset service provider may treat the crypto-asset user and the controlling person as non-reportable persons. 2 If a business relationship with a user is terminated after a change in circumstances and if the re-examination of the business relationship required by the change in circumstances has not been completed by the time of termination, the reporting Swiss crypto-asset service provider need not take the change in circumstances into account in the report.