UBS, the world's biggest wealth management bank, has received a disclosure order from the Swiss Federal Tax Administration that obliges it to transfer information going back to 2006 about HNW accounts to French authorities.

The Swiss authority, according to a UBS press release, received a French request for international administrative assistance in tax matters that concerned some UBS account numbers pertaining to current and former clients domiciled in France; the data comes from 2006 and 2008. Since then, the client base underlying the data has changed significantly and a large number of the accounts affected by the French request have been closed.

The French tax authorities made the request in accordance with the double taxation agreement between Switzerland and France. Pursuant to the FTA's subsequent disclosure order, UBS must send the information to the FTA, which will pass it on to the French.

The bank has expressed its concerns to the FTA that the legal grounds for this request are ambiguous at best. It believes that the data and the justification received as part of the request lack the required specificity. It has informed affected clients about their procedural rights, including the right to appeal. It is also appealing against the request to the Swiss Federal Administrative Court.

The French tax authorities made their request because of data they received from the German authorities. UBS expects other countries to make similar requests as a result of the data on its clients that the Germans have seized over the past few years during their tax investigations and passed on to others.

A UBS press release states that the bank "has largely completed a compliance programme with clients based in Europe, including France," whatever that might mean. The bank muddies the waters further by saying that this manoeuvre entails the "documentation of tax disclosure by its clients."

On 1 January 2017, the automatic exchange between states of tax-relevant data about banks' clients will begin in Switzerland. All Swiss banks will have to provide data to the French every year.