Switzerland: First group requests by IRS from Swiss financial institutions

Switzerland: First group requests by IRS

The Swiss federal tax administration on 1 December 2020 published a list of 13 Swiss financial institutions in response to an administrative assistance request from the IRS concerning certain U.S. accounts.


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The IRS (the U.S. tax authority) in October 2020 requested administrative assistance from the Swiss federal tax administration to obtain information from 13 Swiss financial institutions concerning recalcitrant U.S. accounts and accounts of nonparticipating foreign financial institutions that were reported to the IRS in aggregated form for the years 2014 to 2019. These group requests reflect measures in the 2009 Protocol to the Switzerland-United States income tax treaty to allow the IRS to issue group requests in connection with the FATCA reporting of Swiss financial institutions.

The Swiss federal tax administration on 1 December 2020 published in the official gazette the list of the 13 Swiss financial institutions. The publication of this list serves as a notification to all persons entitled to appeal (i.e., the contracting parties, their legal successors and any other parties to the account relationships concerned) to the Swiss federal tax administration, as required by law. These parties have 20 days from the publication date of 1 December 2020 to appeal against the intended transmission of their data to the IRS.  

KPMG observation

It is expected that the IRS could make more group requests in the coming weeks and months in relation to other Swiss financial institutions.

Read a December 2020 report prepared by the KPMG member firm in Switzerland

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