Swiss Federal Council Adopts Dispatch On Italy DTA
The Swiss Federal Council has adopted a dispatch on the implementation of a tax information exchange protocol to its double tax agreement (DTA) with Italy.
The protocol to the 1976 DTA was signed on February 23, 2015. It brings its information exchange provisions into line with the Organisation for Economic Cooperation and Development’s Model Tax Convention. According to the Swiss Federal Council, the protocol will support and expand bilateral relations and facilitate the regularization of Swiss banks’ Italian clients under Italy’s voluntary disclosure program.
The Federal Council said that the amendment had generally been welcomed by the cantons and business groups who participated in a consultation on the proposed change. The federal decree on the adoption of the protocol is subject to an optional referendum.
The Council confirmed that work is underway on the implementation of the roadmap on tax cooperation also signed in February.
The roadmap establishes that, in principle, financial institutions and their employees are not responsible for the tax offences of their clients. It stipulates that Italian taxpayers with an account in Switzerland should be able to take part in Italy’s voluntary disclosure program under the same conditions as Italy offers for accounts in other countries. Group information exchange requests will be permitted, and the roadmap paves the way for Switzerland’s removal from Italy’s “black list.”
