ARTICLE · 28 FEBRUARY 2018

Effects Of Automatic Exchange Of Information On Voluntary Disclosures

Ernst & Young

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In 2018, Switzerland will start executing the Automatic Exchange of Information (AEOI) since it will, for the first time, be transmitting to other countries the data collected from Swiss financial institutions...

SwitzerlandTax

Jean-Marie Hainaut

Dominik Bürgy

Roger Krapf

Frédéric Bonny

In 2018, Switzerland will start executing the Automatic Exchange of Information (AEOI) since it will, for the first time, be transmitting to other countries the data collected from Swiss financial institutions in 2017, and also receiving from those countries information on the financial assets held outside Switzerland by Swiss taxpayers. The question has arisen as to what impact AEOI will have on Swiss taxpayers' right to regularize their tax position by disclosing unreported income and wealth to their cantonal authorities. On 15 September 2017, the Swiss Federal Tax Administration (SFTA) stated its position on the subject by publishing for the first time a position on the effects of AEOI on voluntary disclosures made after 31 December 2017. As the SFTA's information document was drawn up in collaboration with the "fiscal criminal law" working group of the Swiss Tax Conference (CSI/SSK), it can be assumed that the cantonal tax administrations, which are responsible for

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