精东影业

The topic of tax information exchange, although seemingly less prominent than in past years, continues to present interesting developments for professionals in the field.
The webinar organized by the 精东影业 Tax & Legal Competence Centre focuses on four key topics. The first concerns the update of the Commentary on the OECD Model Tax Convention and the possibility for the Swiss Federal Tax Administration (FTA) to use the information received also against third parties without submitting a new request for administrative assistance. Secondly, the issue of errors caused by the holder of the information will be addressed, as such errors may lead to the exchange of taxpayer data even when the taxpayer does not meet the foreign state's criteria for submitting a group request. In this scenario, the question arises of how the taxpayer can defend themselves before the tax authority of the requested state, particularly in Switzerland.
The third topic examines Form A, which was the subject of a recent ruling by the Swiss Federal Supreme Court (Decision No. 2C_1010/2022 of July 23, 2024). According to the court, Form A serves to identify the beneficial owner of a banking relationship and, as such, represents presumably relevant information that must be transmitted to the requesting state. However, it is permitted to redact the date of completion of Form A if it predates the period covered by the request.
Finally, the United States and Switzerland have agreed to transition from FATCA Model 2 to Model 1. It is therefore crucial to understand what will change for the financial institutions involved and what information they will be able to obtain from the United States under the principle of reciprocity.

Program and Speakers
The usability of information received by the FTA against third parties
Tania Cuc猫
MLaw, Team Leader, Division for the Exchange of Tax Information, Swiss Federal Tax Administration (FTA), Bern

How to handle errors made by the holder of the information
Emanuele Stauffer
Attorney, former public prosecutor, Partner at Studio Legale Bertoli Stauffer Cappa, Lugano, Chairman of the Board of Directors of Casin貌 di Lugano SA

Form A as presumably relevant information
Simone Aldi
Attorney, Clerk at Court I of the Swiss Federal Administrative Court (TAF)

The transition from FATCA Model 2 to Model 1 for Switzerland and compliance with the principle of reciprocity
Incoronato Sammarone
Dott., Senior Legal Advisor, BRP Bizzozero & Partners, Lugano

Cost
CHF 350
CHF 50 discount for members of partner organizations

Registration


Registration Deadline
Thursday, June 12, 2025