Switzerland: Negotiations with United States to switch from non-reciprocal FATCA Model 2 to reciprocal Model 1
Finalization of negotiations between Switzerland and the United States
Finalization of negotiations between Switzerland and the United States
The State Secretariat for International Finance (SIF) of Switzerland in November 2023 released an update announcing the finalization of the negotiations to transition from non-reciprocal FATCA Model 2 IGA (Intergovernmental Agreement) to reciprocal FATCA Model 1 IGA for the automatic exchange of tax information between Switzerland and the United States.
Overview
Switzerland originally signed a FATCA Model 2 IGA with the United States in June 2014, which required Swiss financial institutions to directly disclose account details to the U.S. tax authority (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 United States must request this data through regular administrative assistance channels. Switzerland had previously indicated its intention to switch to Model 1.
The Federal Council in October 2014 approved the negotiation mandate with the United States for the switch to Model 1 IGA.
Negotiations were finally concluded on 13 November 2023 and preparations for the signing are currently in progress. Once implemented, Switzerland will receive account details from the IRS.
Read a December 2023 report [PDF 399 KB] prepared by the KPMG member firm in Switzerland
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