Swiss Federal Councillor and head of the Federal Department of Finance (FDF)
Eveline Widmer-Schlumpf recently held talks with French Finance Minister François
Baroin, with the discussions focussing on the global economic situation, on
the current crisis in the eurozone, and on bilateral and multilateral tax matters.
During the course of the debate, Swiss Federal Councillor Widmer-Schlumpf underlined
the importance of close relations between the two countries and alluded to the
major role that France plays as Switzerland’s third largest commercial
trading partner.
The head of the FDF underlined Switzerland’s interest in finding a lasting
solution to the debt crisis in the eurozone, noting that Switzerland, as a member
of the International Monetary Fund (IMF), has contributed to financial assistance
programmes for indebted countries.
The two finance ministers discussed implementation of the existing Franco-Swiss
double taxation agreement (DTA). Federal Councillor Widmer-Schlumpf underscored
the willingness of Switzerland to collaborate with France within the framework
of the negotiated agreements, and emphasized the significant efforts made by
the Confederation to apply the Organization for Economic Cooperation and Development’s
(OECD) international standards in tax matters.
Widmer-Schlumpf ended by alluding to recent criticisms from France regarding
Swiss collaboration in tax matters.
The two ministers agreed to hold further talks in Switzerland at the beginning
of 2012.
Back in April, Switzerland announced plans to amend the existing bilateral
DTA with France, explaining that the treaty, approved by parliament on June
18, 2010, would be supplemented with an interpretation clause, stating that
the requirements for an administrative assistance request should not hinder
an effective exchange of information.
At the time, the Swiss Federal Administration explained that as a result of
the new clause, Switzerland and France would be bound by the requirements set
out in the agreement for an administrative assistance request not to be interpreted
in a formalistic and restrictive manner.
It stated that: “In accordance with the Federal Council decision of February
13, 2011, in future indicating the name and address of the taxpayer and the
information holder is no longer absolutely necessary for processing administrative
assistance requests, provided that the identification occurs by other means
and fishing expeditions are not involved.”
However the French
government is still calling for an automatic exchange of tax information between
countries, a solution that has already been adopted by the European Union (EU),
and which is expected to enter into force in 2013, despite continuing opposition
from Luxembourg. The EU would like to extend this provision to third countries such
as Switzerland.
Despite advances from and talks with the Confederation, France has reportedly ruled
out the idea of concluding a bilateral tax deal with Switzerland, similar to those negotiated with the UK and Germany.
Although the French authorities are urgently seeking additional revenues, including recourse to increased taxation of the country’s
wealthiest, the French finance and budget ministries are said to have dismissed the idea of
such an agreement, even though a deal would undoubtedly serve to yield much-needed
tax revenues.
Undeclared assets held by French taxpayers in Swiss accounts have been estimated
at around CHF90bn (USD114bn).