What changed

(Simplified procedure – Rule 52(1) of the Rules of Procedure)

P10_TA(2025)0273

PR_NLE-CN_Agreement_app

EU-Switzerland agreement on the automatic exchange of financial account information: Amending Protocol

Symbols for procedures

Committee on Economic and Monetary Affairs

* Consultation procedure

PE778.334

*** Consent procedure

European Parliament legislative resolution of 13 November 2025 on the proposal for a Council decision on the conclusion, on behalf of the Union, of the Amending Protocol to the Agreement between the European Union and the Swiss Confederation on the automatic exchange of financial account information to improve international tax compliance (COM(2025)0376 – C10-0199/2025 – 2025/0199(NLE))

***I Ordinary legislative procedure (first reading)

***II Ordinary legislative procedure (second reading)

***III Ordinary legislative procedure (third reading)

(The type of procedure depends on the legal basis proposed by the draft act.)

Amendments to a draft act

Amendments by Parliament set out in two columns

Deletions are indicated in bold italics in the left-hand column. Replacements are indicated in bold italics in both columns. New text is indicated in bold italics in the right-hand column.

The first and second lines of the header of each amendment identify the relevant part of the draft act under consideration. If an amendment pertains to an existing act that the draft act is seeking to amend, the amendment heading includes a third line identifying the existing act and a fourth line identifying the provision in that act that Parliament wishes to amend.

Amendments by Parliament in the form of a consolidated text

New text is highlighted in bold italics. Deletions are indicated using either the ▌symbol or strikeout. Replacements are indicated by highlighting the new text in bold italics and by deleting or striking out the text that has been replaced.

By way of exception, purely technical changes made by the drafting departments in preparing the final text are not highlighted.

DRAFT EUROPEAN PARLIAMENT LEGISLATIVE RESOLUTION

on the proposal for a Council decision on the conclusion, on behalf of the Union, of the Amending Protocol to the Agreement between the European Union and the Swiss Confederation on the automatic exchange of financial account information to improve international tax compliance

(COM(2025)0376 – C100199/2025 – 2025/0199(NLE))

(Consultation)

2. Instructs its President to forward its position to the Council, the Commission and the governments and parliaments of the Member States and of the Swiss Confederation.

EXPLANATORY STATEMENT

The proposal is an opinion to the Amending Protocol to the Agreement between the European Union and the Swiss Confederation on the automatic exchange of financial account information to improve international tax compliance, which was concluded in 2015.

The Agreement provides the legal basis for the reciprocal automatic exchange of financial account information between the Member States and the Swiss Confederation. The main objective of the Amending Protocol is to improve administrative cooperation in the area of direct and indirect taxation in the following ways:

● to ensure that the automatic exchange of financial account information is in line with the updated Common Reporting Standard (CRS) developed by the Organisation for Economic Cooperation and Development (OECD) and with the respective EU rules. i.e. the Council Directive (EU) 2023/226 (DAC8), which implemented the latest amendments to the CRS within the EU. It should be highlighted that as a result of the recent update of the CRS, its scope was extended to cover electronic money products and central bank digital currencies. Furthermore, the updates also contain provisions to ensure an efficient interaction between the CRS and the separate Crypto-Asset Reporting Framework;

● to ensure mutual assistance in the recovery of VAT claims. It should be underlined that the amendments align as much as possible with the relevant provisions of the EU-Norway Agreement, which, in turn, replicates the EU Recovery Directive;

● to update the legal reference on data protection legislation: all the references to the repealed Directive 95/46/EC were removed and replaced with references to the GDPR (i.e. Regulation (EU) 2016/679). It should be noted that Switzerland is the beneficiary of an EU adequacy decision concerning data protection.

Including the above listed changes to the Agreement would result in better cooperation based on common rules and enhance the fight against tax evasion and money laundering, thus bringing added value for both the Member States and Switzerland. The modifications of CRS will apply from 1 January 2026 and - in line with that - the respective provisions of DAC8 will apply in the EU from that onwards.

According to Article 218(6)(b) TFEU, the Council can only adopt the decision to conclude the agreement after the European Parliament gives its opinion.

The rapporteur welcomes the conclusion of the Amending Protocol to the Agreement between the European Union and the Swiss Confederation on the automatic exchange of financial account information as it is an important step in continuing and deepening the administrative tax cooperation between the parties. In line with the new Article 4s inserted into the Agreement by Article 1 (8) of the Amending Protocol, the rapporteur urges the Member States and Switzerland to take all necessary measures to explore the extension of the mutual assistance to other - direct and indirect - tax claims within a four-year period following the first day of January after the signature of the Amending Protocol.

In view of the technical nature of the proposal and the urgency of adopting the proposal, your rapporteur proposes that Parliament approves the proposal without amendments pursuant to a simplified procedure without amendments (rule 52). However, the rapporteur would like to raise that the Parliament should be involved at an earlier stage of the process and have more time to prepare its opinion next time.

ANNEX: DECLARATION OF INPUT

The rapporteur declares under her exclusive responsibility that she did not include in her report input from interest representatives falling within the scope of the Interinstitutional Agreement on a mandatory transparency register, or from representatives of public authorities of third countries, including their diplomatic missions and embassies, to be listed in this Annex pursuant to Article 8 of Annex I to the Rules of Procedure.

PROCEDURE – COMMITTEE RESPONSIBLE

Title

Amending Protocol to the Agreement between the European Union and the Swiss Confederation on the automatic exchange of financial account information to improve international tax compliance

References

COM(2025)0376 – C10-0199/2025 – 2025/0199(NLE)

Date of consultation or request for consent

3.9.2025

Committee(s) responsible

Date announced in plenary

ECON

6.10.2025

Rapporteurs

Date appointed

Kinga Kollár

11.9.2025

Simplified procedure - date of decision

13.10.2025

Date adopted

13.10.2025

Date tabled

20.10.2025