Switzerland amends US tax treaty

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2025

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Switzerland amends US tax treaty

swiss-us.jpg

The Swiss parliament yesterday amended its tax treaty with the US allowing the IRS to easily identify US taxpayers with undeclared Swiss accounts.

The amendment sets a course for greater tax information sharing between the two countries. It is also hoped this will relieve some of the pressure the US is putting on Swiss banks, such as UBS, to share information.

Although the Swiss-US treaty has allowed information exchange for a number of decades, Swiss banking secrecy rules have seen the Switzerland interpreting these rules narrowly.

The new treaty will allow the IRS to ask the Swiss authorities to share the names of US taxpayers who exhibit “behavioural patterns” of tax evasion as set out by US law.

FURTHER READING:

Switzerland puts forward new tax compliance model

EXCLUSIVE: Rudolf Elmer explains why he blew the whistle on Julius Bär’s secret evasion activities

Ten things you need to know about the UK-Swiss tax deal

Swiss banks to pay $2.8 billion to Germany in tax evasion deal

more across site & shared bottom lb ros

More from across our site

The hire of Doug Wick expands Baker McKenzie’s state and local tax practice and adds to the firm’s growing ex-IRS expertise
One year after Nuwaru joined the WTS network, leaders James Jobson and Matthew Missaghi reflect on the firm’s mission to offer mid-tier pricing but deliver top-tier results
Join ITR's Head of Research, John Harrison, for an overview of key dates, new developments, best practices, and more for next year’s research cycle
The president’s tariff regime has already caused misery for taxpayers. Losing at the Supreme Court would mean it was all for nothing
The US itself was the biggest loser of tax revenue to American multinationals’ profit shifting, the Tax Justice Network reported; in other news, firms made key tax hires
Identifying who will bear the costs and concerns around confidentiality are issues yet to be resolved, advisers say
As multinationals embed tax technology into their TP functions, a new breed of systems – built on multi-model databases – is quietly transforming intercompany pricing logic
The president described it as ‘one of the most important cases in the history of our country’; in other news, Portugal established a VAT group regime
Clients are facing increased TP audit scrutiny in Hungary. DLA Piper Hungary is therefore using AI and advanced analytics to augment its advice, the firm’s head of TP says
Simpson Thacher & Bartlett and MinterEllisonRuddWatts were among the firms that advised on the deal
Gift this article