Introduction
The Global Forum on Transparency and Exchange of Information for
Tax Purposes (Global Forum) decided in mid-March 2015 that
Switzerland should enter Phase 2 of the Peer Review. This decision
represents a clear statement by the OECD that Switzerland's
legal and regulatory framework for information exchange complies
with internationally agreed standards reflected in Art. 26 of the
OECD Model Tax Convention on Income and on Capital (OECD-MA).
Switzerland is now eligible for Phase 2 of the Peer Review
examining the practical implementation of that framework. The only
member state of the Global Forum that withheld its consent to
Switzerland's entry into Phase 2 was India, which accuses
Switzerland of refusing to cooperate in relation to the
approximately 400 requests for information exchange recently
submitted by India. Switzerland takes the position that these
requests are based on stolen data (essentially stemming from a CD
that is said to have originated
