The Resource AX and another v Federal Tax Administration and another : Case 2C_1174/2014

AX and another v Federal Tax Administration and another : Case 2C_1174/2014

Label
AX and another v Federal Tax Administration and another : Case 2C_1174/2014
Title
AX and another v Federal Tax Administration and another : Case 2C_1174/2014
Contributor
Subject
Language
eng
Summary
Judgment by the Swiss Federal Supreme Court (Second Public Law Division), judgment date 24 September 2015. Mr and Mrs X lived in Paris but in 2010 moved to Geneva. In 2013, the French tax authorities requested information from the Swiss tax authorities relating to the bank accounts maintained by the Xs and transactions through those accounts. The French authorities told the Swiss tax authorities that it was suspected that the Xs were still domiciled in France, were living there and carrying on their main professional activities there. The Xs had failed to reveal the accounts in question to the French tax authorities despite an obligation to do so. The Swiss tax authorities requested the information from the bank concerned, which duly provided it. The Swiss authorities gave the Xs the opportunity to make representations and then passed the information to the French authorities. The Xs challenged the decision to provide the information to the French authorities, arguing that the request failed to show that the information requested was likely to be relevant as the taxpayers were Swiss residents; that the Swiss authorities were obliged carefully to examine the request and determine the question of relevance, and that Swiss domestic banking secrecy law prevented the Swiss authorities from transmitting the information. The tax authorities ruled that the information should be provided and the taxpayers appealed to the Administrative Court, which ruled largely in their favour. The Swiss tax authorities appealed
Citation source
In: International tax law reports. - London. - Vol. 19 (2016), part 1 ; p. 1-43
Geographic coverage
Europe
Language note
  • English
  • French
http://library.link/vocab/relatedWorkOrContributorName
Baker, P
http://library.link/vocab/subjectName
  • case law
  • tax treaty
  • exchange of information
  • disclosure
  • bank secrecy
Label
AX and another v Federal Tax Administration and another : Case 2C_1174/2014
Instantiates
Publication
Label
AX and another v Federal Tax Administration and another : Case 2C_1174/2014
Publication

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