On 14 September 2026, the Federal Tax Administration published new notifications of FATCA group requests. These notifications concern administrative assistance and the proposed transmission of information to the United States; they are not tax assessment notices addressed to account holders.
The procedure described by the FTA allows persons entitled to appeal to submit observations within twenty days of notification. In particular, they may contest the US connection asserted in relation to their data. A final decision must then be issued for each account relationship concerned.
The response can usefully separate identification of the account, the period concerned and the evidence relied on to establish the connection with the United States. A general observation about bank confidentiality does not necessarily address these points. Documentation should focus on the data whose transmission is proposed, without assuming that all of the holder's banking relationships are concerned. The applicable notification is therefore the document to examine before preparing observations.
The first step is thus to match the notification to the banking relationship concerned, then document the holder's position. Providing an address for service in Switzerland enables direct delivery of the final decision. This observations stage must be distinguished from a subsequent appeal against that decision.