Based on Article 28 of the DTT CH-FR the French tax authority requested the Swiss tax authorities to answer several questions regarding A. SAS and B. GmbH. and to submit various documents to verify the “economic reality” or “real” existence and substance of G. Switzerland and to the modalities of their taxation in Switzerland and the “bond subscription agreement” between G. Switzerland and G. Belgium). After examining the request, the Swiss tax authority came to the conclusion that it should be acted upon, whereupon it requested the company to provide it with the information. The Swiss company objected to parts of the request and called it a “fishing expedition” and the case ended up in the Federal Administrative Court. Decision of the Court The appeal of the Swiss company was partly upheld by the Federal Administrative Court. Click here for English translation Click here for other translation ...