Consequences of the AIE on spontaneous denunciations

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    What is the automatic information exchange (AIE)?

    Theautomatic information exchange (AIE) is an international scheme in which Switzerland has participated since 2018. This standard allows a state to request financial information on a taxpayer from another state. This exchange is characterised by an exchange of financial account information. The aim of the AIE is to improve tax transparency and to combat tax fraud.

    The AFC's position paper

    The Federal Tax Administration (FTA) provides the following answer to the question of what consequences the automatic exchange of information (AIE), also known as the "Automatic Exchange of Information", has on the possibility of making a voluntary disclosure.

    Swiss residents' foreign tax elements will be known by the Swiss tax authorities on 30 September 2018

    The FTA considers that the tax elements subject to the AIE will be known to the administration by 30 September 2018 at the latest, so that the denunciation can no longer be considered spontaneous from that date.

    What are the consequences?

    The FTA believes that spontaneous (non-punishable) reporting of such income items will no longer be possible as of 30 September 2018

    Reminder of the advantage of self-declaration: If you self-declare, the FTA will calculate an additional tax on the last 3 years (elements of the deceased) or on the last 10 years (personal elements) but you will not risk any fines or criminal proceedings.


    Romain Clapier

    Je suis le fondateur du cabinet fiscal Allo-Déclaration Suisse, un service de conseil fiscal qui se veut accessible à tous. Expert-comptable diplômé suisse de formation, je maîtrise parfaitement la fiscalité suisse et française des particuliers et notamment celle des frontaliers genevois et vaudois.

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