LISBOA PORTO FUNCHAL SÃO PAULO LUANDA MAPUTO PRAIA MACAU DILI SÃO TOMÉ LISBOA PORTO FUNCHAL SÃO PAULO LUANDA MAPUTO PRAIA MACAU DILI SÃO TOMÉ

Jean Monnet Round Table 30 May 2013

“Rubik Agreement, Global Transparency and the Relations of Switzerland with the European Union in direct tax matters”

2 Fiscal transparency as a global issue

Council Directive Council Directive EUROPEAN UNION 2010/24/EU 2011/16/EU WORK ON THE (concerning mutual (on administrative MATTER assistance for the cooperation in the recovery of taxes) field of taxation)

Global Forum on Tax Transparency and

OECD WORK ON THE Exchange of Information for Tax Purposes MATTER (Exchange of tax information portal and peer reviews for the implementation of the internationally agreed tax standards)

3 www.rfflawyers.com

The “close” relationship between the EU and Switzerland lead to specific measures

Close connections Enhanced cooperation

Historical and cultural backgrounds; Agreement between the EU and

Geographical positioning; Switzerland regarding Savings Directive; Member of OECD, EFTA, Schengen; Double Taxation Agreements; Very important trading partners; Mandate to negotiate fiscal High quality banking services; transparency agreements. Political and economic stability.

4 www.rfflawyers.com Aiming for full tax transparency in the European Union: not quite there yet…

RUBIK AGREEMENTS Guarantee the effective taxation of the “relevant persons”, according to the legislation of their country of residence;

Preserve the secrecy of Swiss banks;

Regulate anonymously past untaxed assets;

Guarantee efective taxation on future assets.

5 www.rfflawyers.com

THANK YOU!

Praça Marquês de Pombal 16 · 6º 1250-163 Lisboa · Portugal T: +351 215 915 220 · F: +351 215 915 244 [email protected] www.rfflawyers.com