On 15 September 2017, the Federal Tax Administration (FTA) published its position in connection with the effects of the AIA on (unpunished) voluntary declarations.
According to the communication of 15 September 2017, the tax administration must therefore assume that the tax factors subject to the AIA are known by 30 September 2018 at the latest. Consequently, from this point in time, self-disclosures are no longer made of one's own accord and a (unpunished) self-disclosure with regard to such tax factors is no longer possible.
For tax factors subject to the AIA that will only exist after 2017 and for tax factors from countries that join the AIA later, this applies analogously to 30 September of the year in which the relevant data exchange takes place (for the first time).
The requirement of the other conditions for (unpunished) voluntary disclosure is not affected by this.
The assessment is the responsibility of the competent cantonal tax administration in each individual case.
The attitude of the FTA can be found here.
