The bank has been told by Swiss authorities to hand over information to France.

The Swiss government has ordered the country’s largest bank and world’s biggest wealth manager, UBS, to transfer information to authorities in France investigating alleged tax dodgers. UBS said it was concerned that French arguments for obtaining such data are, at best, “ambiguous”.

In a statement, UBS said it had been sent a “disclosure order” from the Swiss Federal Tax Administration to “transfer information based on a French request for international administrative assistance in tax matters”.

“The request concerns a number of UBS account numbers pertaining to current and former French domiciled clients and is based on data from 2006 and 2008. Since then, the client base underlying the data has changed significantly and a large number of the accounts affected by the French request are closed,” the Zurich-listed bank said.

In 2009, the Zurich-listed lender was part of a historic agreement under which Swiss authorities allowed the transfer of account details to the US, as part of a settlement UBS reached that year with the US. Since then, pressure on Swiss banks’ provision of secret accounts for foreigners has intensified, and the country’s renowned bank secrecy laws are widely considered to be a dead letter with the advent of the Common Reporting Standard, which kicks in from 2017. 

UBS said it was unhappy with the nature of the French data request.

“The bank has expressed its concerns to the FTA that the legal grounds for this request are ambiguous at best. This includes the view that the data and the justification received as part of the request lack the required specificity. UBS has taken steps to inform affected clients about the administrative assistance proceeding and their procedural rights, including the right to appeal,” UBS said. 

UBS said it intends to take legal steps to have the admissibility of the administrative assistance request evaluated by the Swiss Federal Administrative Court. 

“The request from the French tax authorities is based on data received from the German authorities. As previously reported, German authorities conducted various investigations on tax matters in recent years. Certain data related to UBS clients booked in Switzerland was seized during these investigations and also apparently shared with other European countries,” it continued.

“UBS expects other countries to file similar requests. The information seized also includes data from 2009 mainly related to Swiss-domiciled private clients. UBS has taken steps to inform these clients. They represent a very limited population of the overall client base of the bank in Switzerland. A large part of the data refers to mortgage and pension accounts. The Swiss-domiciled private clients are not part of the French request. UBS has largely completed a compliance program with clients based in Europe, including France. The bank was among the first in the industry to take this step requiring documentation of tax disclosure by its clients.”

The bank added that the French data request should also be seen in light of the fact that as of the start of January 2017, the automatic exchange of tax-relevant client data between states will take effect in Switzerland, under which all Swiss banks will have to provide data to French and other tax authorities on an annual basis.