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Switzerland has openly refused any agreements aimed at curtailing its offshore tax haven

reputation or status. Recently, the Swiss Federal Council has said that the present

structure of Swiss Bank Secrecy is a nonnegotiable condition for Switzerland to continue

its membership of the OECD and its affiliation with the European Union. One

commentary has quoted the Swiss economic minister as saying that the OECD project

was imbalanced and unilateral” and completely untenable for Switzerland. Switzerland

has of course very openly marketed its lump-sum (forfait) tax agreements to wealthy

expatriates who are new residents. The agreement sets out the level of taxation to be paid

by the new resident to the cantonal tax authorities.86

It has been recommended by several international tax experts that a thorough review of

all of the preferential tax regimes worldwide is conducted with a view to reducing the

trend globally and not simply in some pockets of the world such as the Caribbean or in

the Pacific Islands. Without a doubt the OECD report is not as conclusive nor is it as far

reaching in its attack on so called preferential tax regimes.87

It is submitted that it should be the job of the United Nations or the World Trade

Organization or the International Monetary Fund or any other global groupings of rich

and poor nations that decides how the problem of preferential tax regimes should be

solved in an equitable and ethical fashion. The self interest of the OECD countries in

86 87 Ibid Marshall Langer at page 672 argues that the OECD has been very arbitrary in deciding which countries and which part of the world it would attack Specifically, Langer argues..”The OECD has been somewhat arbitrary in its designation of harmful tax havens. In addition to omitting many harmful practices by its own member countries, it has omitted other countries that regularly appear on blacklists named by OECD and non-OECD countries. It would be interesting to find out why the OECD refused to include in its report

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