Switzerland: Tax Treaties

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Article
Swiss Federal Supreme Court Limits Protection Of Attorney-Client Privilege In International Tax Assistance Proceedings
In a new landmark ruling 2C_506/2024 dated 4 May 2026 (intended for publication in the official collection), the Swiss Federal Supreme Court addressed for the first time the scope of attorney-client privilege where correspondence between a lawyer and a domestic tax authority is to be produced by that authority in response to a request made by a foreign state in international tax administrative assistance proceedings.
Switzerland Tax
BK
Bär & Karrer
Article
Tax Crimes Without Borders: A Case Study In Navigating Criminal Tax Exposure In The EU And U.S. From Sensitive Audits To Indictments
As global tax authorities ramp up scrutiny and cooperation, the line between a complex, sensitive civil audit and a criminal tax investigation has never been more difficult to identify. This panel uses a real-world- inspired case study with the panelists playing key roles to explore the high-stakes journey of a taxpayer facing parallel scrutiny in both the European Union and the United States.
Switzerland Tax
BK
Bär & Karrer
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