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Switzerland: Reciprocal FATCA agreement with United States signed

FATCA Model 1 Intergovernmental Agreement (IGA) with the United States for the automatic exchange of tax information

July 1, 2024

The Federal Tax Administration (FTA) of Switzerland on June 27, 2024, issued a press release announcing the signing of the reciprocal FATCA Model 1 Intergovernmental Agreement (IGA) with the United States for the automatic exchange of tax information.

  • Currently, FATCA is implemented in Switzerland under the Model 2 IGA, which requires Swiss financial institutions to directly disclose account details to the Internal Revenue Service (IRS) with the consent of the relevant U.S. clients. In cases when consent is not granted by U.S. clients, the U.S. must request this data through regular administrative assistance channels.
  • Under the Model 1 IGA, the tax authorities of both countries will mutually exchange account data automatically. Swiss financial institutions will be required to report the required data to the FTA, which will then transmit it to the IRS. Similarly, FTA will also receive account data of Swiss taxpayers from the IRS.
  • Switzerland had previously indicated its intention to switch to Model 1 IGA. In October 2014, the Federal Council approved the negotiation mandate with the United States for the switch to the Model 1 IGA. The negotiations were concluded on November 13, 2023. Read TaxNewsFlash
  • In Switzerland, the implementation of this agreement necessitates changes to national law, which will be decided by the Federal Assembly. The transition is expected to take effect on January 1, 2027.

Read a July 2024 report prepared by the KPMG member firm in Switzerland

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