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Swiss agree to honour group requests from France

Thursday, 26 June, 2014

Switzerland and France this week signed an addendum to their tax information exchange agreement, allowing France to request information about unidentified owners of Swiss bank accounts.

The deal was announced after a visit of French finance minister Michel Sapin to Bern on Wednesday. It had already been initialled by his predecessor Pierre Moscovici earlier this year.

The amendment relates to so-called 'group requests'. These are demands for information about classes of accountholders whose names are not known to the enquiring authority but who can be specified in some other way, for example the name of the bank and the specific method used by its clients to avoid taxation.

Until February 2013 Switzerland did not accept such requests from any country, but pressure from the OECD forced it to revise its Tax Administrative Assistance Act to accept them if made in accordance with the OECD standard. Retrospective group requests, relating to periods before 1 February 2013, are still inadmissible.

  • From 1 August this year, Swiss banks can no longer be relied upon to warn their clients that their account details have been passed to their domestic tax authority in response to an assistance request. This practice too has been forced on Switzerland by threats that the jurisdiction may fail the OECD Global Forum's peer review process.