Tax Assistance Accorded by Switzerland: the (New) Dangers

In light of the recent Federal Tribunal (TF) ruling and our experience, we examine the recent practice of our authorities regarding “tax cooperation”, in particular as regards the notion of “information likely to be relevant” and the risks that it can trigger not only for the “assumed” taxpayer – the person initially targeted by a request for tax assistance – but also for persons and entities having been in contact with said taxpayer.