Contributing Lawyers


Cyndee Todgham Cherniak

United States

Susan Kohn Ross


Andrew Hudson

Canada is Consulting with Stakeholders on Updates to Canada-Switzerland Tax Treaty

Negotiations to update the income tax treaty between Canada and Switzerland will commence the week of February 8, 2010, in Bern. This is a positive development that follows-up on the Canada-European Free Trade Association free trade agreement (Canada-EFTA FTA) implementation on July 1, 2009. Improving Canada-Switzerland tax treaty rules will further improve trade between the two countries.

In light to the UBS case and probes by the Canada Revenue Agency into the names of Canadian clients, I would not be surprised if the negotiations include discussions about bank secrecy.  In the context of the negotiations of the tax treaty, I would not be surprised to see dicussions about reciprocity of obligations and, therefore, new reporting obligations on Canaian banks.

Persons whose interests are affected by the negotiations have an opportunity to inform the government of any particular issues of double taxation that might be taken into account during the course of negotiations. The government is particularly interested in learning of any difficulties that might be encountered by Canadians under the tax system of Switzerland.

Persons wishing to offer comments concerning the negotiations may send their views to:

Department of Finance
17th Floor, East Tower
140 O'Connor Street
Ottawa, Canada
K1A 0G5
Fax: 613-992-4450

If you require assistance in preparing representations, please contact Cyndee Todgham Cherniak at 416-307-4168.

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