FATCA agreement
The agreement between Switzerland and the United States on cooperation to simplify the implementation of FATCA entered into force on 2 June 2014. The corresponding implementing act has been in force since 30 June 2014.
The Foreign Account Tax Compliance Act (FATCA) is a unilateral set of US regulations that applies worldwide for all countries. It requires foreign financial institutions to disclose information on US accounts to the Internal Revenue Service or levy a high tax.
The administrative and financial burden associated with the implementation of FATCA is considerable for foreign financial institutions. The FATCA agreement reduces this burden as it makes provision for administrative simplifications for Swiss financial institutions.
Models 1 and 2
FATCA implementation in Switzerland is based on Model 2, which means Swiss financial institutions disclose account details directly to the US tax authority with the consent of the US clients concerned. Where US clients do not give their consent, the United States has to request this data through normal administrative assistance channels.
Since 20 September 2019 – when the protocol of amendment to the double taxation agreement between Switzerland and the USA came into force – FATCA group requests can be made for cases from 30 June 2014. Further information, in particular guidance on preparing FATCA group requests, can be found on the Federal Tax Administration website:
On the basis of the Federal Council mandate adopted on 8 October 2014, Switzerland and the United States negotiated Model 1 of the FATCA agreement and signed it on 27 June 2024. This provides for the automatic and reciprocal exchange of information between the competent authorities. The implementation process is currently under way and the earliest entry into force is scheduled for 1 January 2027. Special transitional provisions have been negotiated to ensure continuity between the Model 2 and Model 1 FATCA agreements.
FATCA Qualification Committee
The FATCA Qualification Committee promotes cooperation between the stakeholders involved. It deals with issues arising from the implementation of the FATCA agreement. However, Switzerland is not autonomous in the interpretation of the agreement. In certain cases, consultation with the USA is required. The assessments reflect the opinion of the FATCA Qualification Committee, which has been consulted together with the relevant US authorities where necessary.
Leadership of the Qualification Committee lies with SIF. The other members include the Federal Tax Administration FTA, the Federal Social Insurance Office FSIO and the following institutions: the Swiss Bankers Association, the Swiss Pension Fund Association, the Swiss Insurance Association, the Asset Management Association Switzerland, SwissHoldings, the Swiss Association of Asset Managers and SIX Group.
Further information
Federal Tax Administration (FTA):
Administrative assistance under FATCA