The “foreseeable relevance” of the information under article 26 of OECD Model Convention.

Di Guglielmo Fransoni -
(Comment to Federal Swiss Tribunal, 24.10.2015) If this were a fairy tale, it would certainly begin as all fairy tales do: Once upon a time. Indeed, some of the statements contained in this judgment of the Federal Court of Switzerland provide a very clear evidence of the change that, in the last decades, has occurred in the attitude towards the exchange of information. But let’s proceed in an orderly way. As it is well known, since 29 April 2000 the first paragraph of article 26 of the OECD Model Convention has been amended so that the object of the exchange of information is no longer the «information as is necessary for carrying out the provisions of this Convention» but the «informat. . .