||1.||Recognition of USA as a participating Jurisdiction of the CRS||
Switzerland's recognition of USA as a participating jurisdiction of the CRS has only one goal. To allow US investment entities such as trusts, unatxed US entities such as LLCs and most funds to hold accounts in Swiss banks and not be reported. This will not stand with the OECD. Indeed the OECD implementation handbook will oblige Switzerland to reverse their outrageous position.
||2.||Signing CAAs in 2016 but collecting info as from 2018||
Switzerland has commenced signing CAAs such as with Argentina, and Mexico but data will only be collected as from 2018, to be exchanged in 2019. This is in direct conflict with the OECD report to the G20 that there will be monitoring that participants stick to their commitments to implement CRS by 2017.
|3.||Switzerand has worked in an additional year delay for low value accounts||
The OECD gave early adopters an extra year to do due dilligence on low value accounts. Yet Switzerland abused the extra year rule, to sneak in an extra year for due dilligence on low value accounts. This is in effect a two year delay or a late late adopter for low value accounts.
Late adopters were given an extra year to get their systems in place, yet Switzerland has disengeniously provided an extra year on top of the extra year to do due diligence on low value accounts. There is no justification for this. In fact with Switzerland being a late-late adopter with say LATAM, it is a late-late-late adopter for low value accounts. And if Switzerland delays signing CAAs with say Russia, then Switzerland will be a late-late-late-late adopter for low value accounts.
The EU Commission has clamped down on Andorra as it allows tax evaders an extra year to close accounts and run away to USA without being reported.
|4.||Demanding market access for financial services as a pre-existing condition to sign CAAs||
Switzerland demands that partners facilitate market access to their financial industry before agreeing to automatically exchange information. This blackmail is clearly unacceptable to the OECD.
||5.||Not electing the wider approach||Switzerland has explicitly not elected the wider approach in collecting info on all non residents. Switzerland is doing its utmost not collect as little information as possible and delay collecting where possible.|
|6.||Switzerand does self assessment of data security and confidentiality of potential partners||
Switzerland is undertaking its own assessment of data security and confidentiality in deciding if a caa should be signed with a country. However the OECD says it will undertake the data security ad confidentiality assessment using object criteria such as the ISO 2700 series and publish a list of counries deemed safe to exchnage info with. Switzerland ignores this.