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מחירי העברה: שווייץ- אוקטובר 2011

13 אוקטובר 2011

Swiss banking giant Credit Suisse has begun informing its U.S. private banking clients that their information is subject to disclosure under a treaty request made by the U.S. authorities.

Swiss banking giant Credit Suisse has begun informing its U.S. private banking clients that their information is subject to disclosure under a treaty request made by the U.S. authorities. 

On November 8, the bank acknowledged that it had been ordered by the Swiss Federal Tax Administration (SFTA) to produce data on client accounts requested by the IRS. The disclosure follows a November 7 report from Reuters detailing the notices sent to its U.S. customers with undisclosed accounts. 

"In connection with the IRS treaty request, the SFTA has issued an order directing Credit Suisse to submit responsive account information to the SFTA. This order is immediately executable and Credit Suisse as an information holder has no right to appeal," said Credit Suisse in a November 2 letter to an unnamed client, according to the Reuters report. 

The Credit Suisse letters are similar to notices sent to UBS clients following the settlement of the John Doe summons enforcement action against the bank. They direct clients to either agree to the disclosure of their account information or challenge the disclosure with the Swiss tax administration. 

In its settlement of the UBS dispute, the Swiss government agreed to relax its interpretation of the term "tax fraud and the like" to include tax evasion for purposes of responding to requests for information through the treaty process. At the time, the Swiss government said that it would be willing to use the expanded definition for accounts in banks other than UBS and signed a protocol to its 1996 tax treaty with the United States to formalize the arrangement. The protocol has been ratified by the Swiss parliament but remains pending before the U.S. Senate. (For the 2009 protocol to the 1996 Switzerland-U.S. income tax treaty, see Doc 2009-21197 or 2009 WTD 183-26; for technical corrections to the protocol, see Doc 2011-12369.) 

The U.S. and Switzerland are currently discussing terms for a settlement to resolve all outstanding questions over tax evasion believed to have been facilitated by Swiss banks for U.S. clients. Switzerland has successfully negotiated arrangements with Germany and the United Kingdom in which the Swiss government will collect withholding taxes on undeclared accounts and remit the proceeds to the account holders' country of residence. The agreements are viewed by Switzerland as a way to preserve bank secrecy while satisfying demands that it not provide an avenue for tax evasion. (For prior coverage, see Doc 2011-22466 or 2011 WTD 215-11.) 

In July, Credit Suisse issued a statement acknowledging that it was the target of a U.S. criminal probe into alleged tax evasion. 

In its third quarter earnings report released November 1, Credit Suisse said that it had made a litigation provision of CHF 295 million (about $330 million) for its private banking division in relation to the U.S. investigation. 

**The information contained on this website and from any communication related to this website is for informational purposes only and does not constitute any legal, financial or other advice. For specific tax advice you should contact a qualified professional.