The case
Automatic exchange of tax information between Switzerland and the US: Negotiations for the switch from non-reciprocal FATCA Model 2 to reciprocal FATCA Model 1 were concluded on 13 November 2023. Preparations for signing are now underway. Upon entry into force, Switzerland will receive account details from the US tax authority.
The commentary
In 2014, the Federal Council approved of the mandate for negotiations with the United States to switch to Model 1, which provides for the reciprocal automatic exchange of information. It is expected that this change could lead to “re-papering” and that client relationships may have to be re-documented.
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