Law Commons^™

The past few years have seen some fundamental changes in the exchange of information relating to tax matters. The growing number of Double Taxation Agreements (DTAs) containing new clauses based on Article 26 of the OECD Model Convention as well as new types of mechanisms favoring fiscal data transfers raise issues inducing different approaches for tax practitioners. At the same time, international administrative assistance in banking and financial matters has reached a certain maturity. It is therefore worth confronting this rich experience with a few of the legal questions that will undoubtedly arise in the implementation of the Swiss Federal …