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Swiss Court orders review of transfer of two UBS files


The Swiss Federal Administrative Court blocked, on 15 July 2010, the transfer of information on two unnamed US clients of Swiss bank UBS to the US tax authorities and referred their cases back to the tax administration for further review.

It found that the UBS clients had not received a sufficient hearing by the Swiss Federal Tax Administration (FTA) in determining whether their banking details should be disclosed to the US under the 2009 agreement to resolve the UBS case. The FTA had to allow the two clients an opportunity to comment before issuing new rulings in their cases.

The agreement requires the FTA to complete the processing of UBS client files by 26 August. Details on 2,500 of the estimated 4,450 UBS accounts of US taxpayers have so far been transmitted to the IRS, according to a report in Neue Zurcher Zeitung on 19 July. A further 900 files are still being considered, while 850 have been completed but are still within the period during which an appeal can be considered.

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