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Canada and Switzerland have agreed to an automatic exchange of financial information beginning in 2017 with the first transmission of data in 2018. Once Canada has been provided with such information it can ask Switzerland for information with respect to prior years under the provisions of its tax treaty with Switzerland. In anticipation of audits arising from such exchanges and requests, we asked our Zurich counsel,  Dr. Roberto Dallafior, of Nater Dallafior, to provide us a brief review of what information the Swiss banks will provide where a treaty request is made as well as what information will be provided where the customer makes the request (presumably because the customer has been compelled to do so). Dr. Dallafior’s memorandum is available here.