All Swiss double taxation agreements renegotiated since March are in line with Organisation for Economic Co-operation and Development standard on administrative assistance in tax matters, the state said in a recent official statement.

Switzerland will in future provide administrative assistance upon what the statement referred to as “justified request in individual cases”. However, so-called "fishing expeditions" will not take place.

This means that the taxable person must be clearly identified and, in the case of banking information, the bank must also be identified. This will also apply to future requests from France, regardless of the fact that the Franco-Swiss DTA in this regard contains a different wording compared with other renegotiated DTAs.

The wording chosen by France allows a French request to not directly name the bank if it can be identified otherwise, for example through supplying the bank’s IBAN number. Therefore French requests will not deviate in practice from those of other countries with which Switzerland has a DTA.

Thus it remains that the Swiss Federal Tax Administration will not provide administrative assistance to a foreign tax authority if the bank is not clearly identified.

Since March, the Swiss Federal Council decided to open negotiations on 14 double taxation agreements that will together remove the Alpine state from the “grey-list” of OECD jurisdictions that have promised to sign such deals but have not yet done so.

So far DTAs with Austria, Denmark, Luxembourg, France, Norway, and the UK have been signed. The Swiss Federal Council has also recently approved the signing of DTAs with Finland, Mexico and the USA. The DTAs with Japan, the Netherlands, Poland, Qatar and Singapore are already initialled but remain to be approved by the Federal Council and then signed.