Swiss Announcement that It will Continue to Drag Its Feet, but Marginally Less So (Perhaps), on Double Tax Treaty Administrative Assistance Requests

The Swiss have announced a relaxed, perhaps, interpretation of their Double Tax Agreement ("DTA") Administrative Assistance provisions. The announcement is here. The action was prompted by OECD peer pressure. Basically, the Swiss signal tax cheats (and other criminals who desire, shall we say, discretion) that the Swiss will generally only respond to administrative requests only when the depositor and the financial institution is named in the request.  Often, as in the UBS / U.S. recent spat, the requesting treaty partner will not know the names of the depositors, so the general requirement that the requesting treaty partner name names -- generally -- means that the Swiss can continue to offer secrecy -- generally.
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