A good article
(hat tip Mark Herkenrath) in India's Business Standard, outlining how slippery it can be trying to sign a decent tax treaty with Switzerland. Here are just a couple of excerpts:
What would it really take to get black money back from tax havens to India? The first thing would be to understand one simple thing about tax havens: they are extremely hard to crack. They are not just waiting to hand over information and money; they are doing all in their might to do exactly the opposite.
Indeed. Instead of commenting further, we'd suggest just reading the article in full. Still, here is a taster:
Interestingly, in a unilateral amendment Switzerland made to the DTA with India on the October 6, it was spelt out that a person under investigation may be identified, if necessary, by means “other than name and address” and the bank connection must be identified only “to the extent known”. This sounds good. But the same paragraph notes that Switzerland will, in practice, apply the principles of “proportionality” and “practicability”. This means that Switzerland can still decline any request without a clear indication of which bank exactly is holding the requested information. Confusing, isn’t it?
Yes it is. It's worse than that. More here