Court Decision Expands Admissibility of Group Information Requests

A recent decision (A-6385/2012) by the Swiss Federal Administrative Court opens the door to ‘‘group’’ information requests covering past tax periods under the 1996 Switzerland-U.S. tax treaty and many other Swiss tax treaties. The court further held that a rejected information request may be updated and resubmitted.

A group request is an administrative assistance request for information about a group of taxpayers from a single country who might hold financial assets in a second jurisdiction and cannot be identified individually. The court’s June 6 decision involved a second, restated request by U.S. authorities for information about accounts held by U.S. individuals at Credit Suisse. The request covered tax years 2002-2010. (...)