The French tax authorities have increased pressure on UBS in France over allegedly helping wealthy clients evade tax. The Swiss banking giant does not want to admit defeat yet.


Switzerland’s largest bank has received a disclosure order from the Swiss Federal Tax Administration (FTA) to hand over French client data, UBS announced Tuesday.

The French tax authorities made a request to the FTA for international administrative assistance in tax matters, the bank said in a statement. The request is based on a double-taxation agreement between Switzerland and France.

The FTA has accepted the request and directed a disclosure order to UBS. The request from the French tax authorities is based on data received from the German authorities.

Ambiguous Legal Grounds

The request concerns a number of UBS account numbers from 2006 and 2008. Since then, the client base underlying the data has changed significantly, UBS claims. A large number of the accounts affected by the French request have since been closed, the statement added.

The bank has expressed its concerns to the FTA that the legal grounds for this request are ambiguous at best. UBS holds the view that the data and the justification received as part of the request lack the required specificity.

UBS Resists

UBS has taken steps to inform affected clients about the administrative assistance proceeding and their procedural rights, including the right to appeal.

In addition, UBS said it plans to take legal steps to have the admissibility of the administrative assistance request evaluated by the Swiss Federal Administrative Court.

UBS Paid Guarantee

The French authorities accuse UBS of having concealed billions of euros from the French tax authorities between 2004 and 2012 through the use of a sophisticated system of secret transactions. In 2014 French judges ordered the Swiss bank to pay a guarantee of 1.3 billion Swiss francs pending the completion of the investigation into alleged tax evasion.

The French subsidiary of UBS had to pay a fine of 10 million euro three years ago. Meanwhile, former employees of the bank in France are under investigation.