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France; Switzerland: Exchange of Bank Information for Tax Purposes

(June 25, 2009) On June 12, 2009, France and Switzerland agreed to amend their existing bilateral tax treaty by adding a provision that allows the exchange of bank information for tax purposes, bringing the treaty up to the standard of the Organisation for Economic Co-operation and Development (OECD) Model Tax Convention (OECD, Centre for Tax Policy and Administration, OECD Model Tax Convention on Income and on Capital – An Overview of Available Products,,3343,en_2649_33747_1913957_1_1_1_1,00.
(last visited June 22, 2009)). The new provision will take effect on January 1, 2010. It will contribute to the fight against fraud and tax evasion.

The French tax authorities will be able to obtain banking information for tax purposes without restriction, and Switzerland will not be able to oppose requests for such information on the grounds of bank secrecy. Luxembourg signed a similar agreement with France on June 3, 2009. (Press Release, Ministry of Budget, Suites du G20: paragraphe d'un avenant à la convention fiscale franco-suisse permettant la levée du secret bancaire dans les échanges d'information entre administrations fiscales (June 12, 2009), available at