Swiss Information Exchange

On October 22, 2010, Canada signed an information-exchange agreement with Switzerland. The agreement allows CRA to request information on Canadian taxpayers from their Swiss counterparts. This agreement is seen as a major step towards improving compliance given the growing number of tax investigations involving Swiss bank accounts.

It should be noted that there are limitations on the utility of the information-exchange agreement. The agreement doesn’t give CRA the right to undertake “fishing expeditions” – investigations where CRA looks for information without a specific target. Instead, the agreement allows the CRA to request specific information about particular taxpayers based on information that they already know – for example, if CRA suspects that an individual has a Swiss bank account at Credit Suisse, they can now ask it to confirm whether this is so and to provide any information that would lead to a tax liability in Canada.