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Switzerland: Switzerland's first tax info exchange pacts to take effect

05 November 2014   (0 Comments)
Posted by: Author: Ulrika Lomas
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Author: Ulrika Lomas (

Switzerland's tax information exchange agreements (TIEAs) with Jersey, Guernsey, and the Isle of Man have entered into force and will be effective from January 1, 2015.

The Swiss Federal Council announced on November 3 that the treaties entered into force on October 14, 2014. They are the first of Switzerland's seven TIEAs to enter into force. The TIEA with the Isle of Man was signed in August 2013. The deals with Jersey and Guernsey were concluded within days of each other, in September 2013.

On April 4, 2012, the Federal Council decided to adopt the international administrative standard in both its double taxation and tax information exchange agreements.

Last month, the Federal Council adopted definitive mandates for negotiations with other countries to introduce the new global standard for the automatic exchange of information in tax treaties. The Council also launched a consultation on legislation for the unilateral application of the Organisation for Economic Cooperation and Development's (OECD's) Standard on the Exchange of Information to all double tax agreements (DTAs) that are not already in line with the model.

The proposed mechanism would be a transitional measure; once a state or territory becomes able to exchange information upon request with Switzerland on the basis of a DTA in conformity with the OECD standard or another international agreement, the legislation would no longer be applicable to that jurisdiction.

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Section 240A of the Tax Administration Act, 2011 (as amended) requires that all tax practitioners register with a recognized controlling body before 1 July 2013. It is a criminal offense to not register with both a recognized controlling body and SARS.


The Act requires that a minimum academic and practical requirments be set to register with a controlling body. Click here for the minimum requirements of SAIT.

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