Milestone Swiss-US agreement opens prospect of requests back to 2009

A key amendment to the Switzerland-US double taxation agreement came into force on 20 September, allowing Washington to request information from the Swiss on financial accounts going back ten years.

The most important clause removes the distinction between tax evasion and tax fraud in both individual and group requests for exchange of tax information, making it easier for the US to obtain information from Switzerland that ‘may be relevant’ to US taxes. This is in line with the international standard on the exchange of information upon request, which Switzerland already applies to more than 100 states and territories, but not, to date, to the US.

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