Our clients have maintained accounts in Switzerland, for many years. Are they affected by the new Italy/Switzerland DTA, due to come into force in 2015? We have been advised that the agreement has similar characters to the UK/Swiss disclosure agreement. Under that agreement relevant persons can instruct their Swiss paying agents to make a disclosure to preserve the anonymity of the account holder.

There is already a dta since 1974, so the new legislation, which does not yet exist, will not have a retroactive effect.