The automatic exchange of financial account information and FATCA

The Swiss network in 2025

Chapter E.II traced how Switzerland adopted the Common Reporting Standard (CRS), why it chose to collect data from 2017 and to exchange them from 2018, and how the Agenzia delle Entrate uses the Swiss data in its compliance letters. The present section takes up the network as it stands today and the amendments that took effect on 1 January 2026. In the exchange of September 2025 Switzerland exchanged information with 110 states and territories. With 84 of them the exchange was reciprocal. From 26 states Switzerland received data without sending any: 13 did not meet the international requirements on confidentiality and data security, while in 13 further cases Switzerland itself refrained from sending data. No data were exchanged with Russia. Swiss financial institutions reported about 3.8 million accounts, and Switzerland received information on about 3.5 million accounts of Swiss residents held abroad.¹

The relationship with Italy is governed by the agreement between Switzerland and the European Union on the automatic exchange of financial account information, which replaced the savings agreement of 2004 by the Protocol of 27 May 2015. Italy belongs to the group of reciprocal partners, so that the Ticino tax administration receives Italian account data on Ticino residents in the same way as the Agenzia delle Entrate receives Swiss data on Italian residents.² The reciprocal flow matters for the growing number of Italian nationals who have moved to Ticino and kept accounts at Italian banks. Their Italian accounts are reported to the Federal Tax Administration and through it to the canton, which checks them against the wealth tax return.

Who reports and who is reported

The reporting duty falls on Swiss financial institutions: banks, custodial institutions, certain insurance companies and investment entities. Investment entities include collective investment schemes and, of particular importance in Lugano, trusts and companies whose gross income is primarily attributable to investing in financial assets and which are managed by another financial institution.³ A Ticino SA that holds a securities portfolio managed by an independent asset manager under a discretionary mandate may therefore itself be a reporting financial institution. A passive nonfinancial entity, by contrast, is looked through by the bank, which reports its controlling persons. The classification of Lugano holding companies, Liechtenstein foundations and trusts administered by Ticino trustees has been one of the most technical tasks of the local compliance industry since 2017.⁴

The concept of controlling person in the CRS is drawn from the FATF definition of beneficial owner. It therefore coincides largely with the beneficial owner of the TJPG, although the CRS treats all settlors, trustees, protectors and beneficiaries of a trust as controlling persons regardless of control.⁵ The coincidence will make it easier for the Federal Tax Administration to cross-check AEOI data against the transparency register, since the tax authorities belong to the authorities with access to the register.

Notes

1. finews.ch, 10 October 2025 (above). ↩
2. Agreement of 26 October 2004 between the Swiss Confederation and the European Union on the automatic exchange of financial account information to improve international tax compliance, SR 0.641.926.81, amended by the Protocol of 27 May 2015, approved by the Federal Assembly on 17 June 2016 and in force since 1 January 2017, https://www.droit-bilingue.ch/de-fr/0.6/0.64/0.641.926.81-preface-1.html. On the history see Chapter E.II. ↩
3. Federal Act on the International Automatic Exchange of Information in Tax Matters of 18 December 2015 (AEOI Act), SR 653.1, Art. 2, in conjunction with the CRS, Section VIII.A.6 (investment entity), and the Federal Tax Administration's guidance Wegleitung Standard für den automatischen Informationsaustausch über Finanzkonten. ↩
4. CRS, Section VIII.D.9 (passive non-financial entity) and Section VIII.D.6 (controlling persons); OECD, Commentaries on the Common Reporting Standard, on trusts and foundations. ↩
5. CRS, Section VIII.D.6, and its Commentary, under which the settlor, trustee, protector and beneficiaries of a trust are always treated as controlling persons. ↩

For general information only. This article does not constitute legal or tax advice, does not replace advice on an individual case and creates no lawyer-client relationship. It reflects the legal position as of October 2026.