Undeclared bank accounts in Switzerland

On August 27th, 2009 France and Switzerland signed a new double taxation treaty which enables France to obtain information on banking assets in the case of a tax evasion as well as a tax fraud.

The French authorities already announced a list of 3,000 taxpayers who have non-declared assets in Switzerland. These taxpayers are invited to undertake a "voluntary disclosure" before January 1st, 2010 and thus benefit from favorable conditions when negotiating the regularization of their affairs in France.

This pressure follows the action of the US Internal Revenue Service which issued on August 19th, 2009 a "John Doe Summons" to UBS AG (a corporation established under the laws of the Swiss Confederation) seeking information concerning client accounts.