The Resource Article 26 of the OECD Model Tax Convention - group requests - the birth of a new international standard? Recent developments in Switzerland and potential ramifications for other jurisdictions

Article 26 of the OECD Model Tax Convention - group requests - the birth of a new international standard? Recent developments in Switzerland and potential ramifications for other jurisdictions

Label
Article 26 of the OECD Model Tax Convention - group requests - the birth of a new international standard? Recent developments in Switzerland and potential ramifications for other jurisdictions
Title
Article 26 of the OECD Model Tax Convention - group requests - the birth of a new international standard? Recent developments in Switzerland and potential ramifications for other jurisdictions
Creator
Subject
Language
eng
Summary
In a recent decision, the Swiss Federal Court held that a group request from the Inland Revenue Service (IRS) which did not name the taxpayer was not a fishing expedition. Credit Suisse was ordered to hand over information relating to US taxpayers who hold bank accounts with the bank through offshore vehicles. In a separate move, the legality of which has been called into question by legal commentators, the Swiss government held that group requests based on a factual pattern represent a generally accepted international standard which binds Switzerland, at least going forward. This note considers whether the Swiss Court has effectively imported US legal principles into Swiss law and whether its reasoning is confined to the US treaty or whether it may be extended to other existing double tax treaties entered into by Switzerland
Citation source
In: British tax review. - London. - (2014),
http://library.link/vocab/creatorName
Noseda, F
Geographic coverage
  • Europe
  • North America
Language note
English
http://library.link/vocab/subjectName
  • tax treaty
  • exchange of information
  • case law
  • OECD Model
  • bank secrecy
Label
Article 26 of the OECD Model Tax Convention - group requests - the birth of a new international standard? Recent developments in Switzerland and potential ramifications for other jurisdictions
Instantiates
Publication
Label
Article 26 of the OECD Model Tax Convention - group requests - the birth of a new international standard? Recent developments in Switzerland and potential ramifications for other jurisdictions
Publication

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