The Swiss Federal Council has approved the first six double taxation agreements (DTAs) that include the article on administrative assistance in accordance with Art. 26 of the OECD Model Convention, and authorised their signature by the Federal Department of Foreign Affairs (FDFA) and the Federal Department of Finance (FDF). Reportedly, the FDF will submit a dispatch to parliament in November, including the request for parliament to consider the issue of an optional referendum.
The six DTAs include Denmark, Luxembourg, Norway, France, Mexico and the UK . With each DTA, a report was sent to the cantons and to business associations with an interest in the DTAs and they were asked to provide their comments. They all welcomed the conclusion of the DTAs.
Following the signing of the DBAs by both contracting States, each of the texts of agreements will be published. Since the Federal Council decision of 13 March 2009 on the extension of administrative assistance in tax matters, Switzerland has negotiated a revised administrative assistance clause in accordance with Article 26 of the OECD Model Convention in the DTAs with thirteen states. DTAs containing the extended administrative assistance clause have also been initialled with the USA, Japan, the Netherlands, Poland, Austria, Finland and Qatar. These DTAs will be submitted to the Federal Council in the near future so that it may approve their signature.
In order to be removed from the so-called “grey list” compiled for the G-20 by the OECD Secretariat, twelve agreements meeting the OECD standard on administrative assistance must be signed.