Facts
On 2 April 2015, the Federal Central Tax Office of the Federal Republic of Germany (BZSt) submitted a request for administrative assistance to the Swiss Federal Tax Administration (ESTV). It requested information about an unnamed "German taxpayer" who held a numbered account at the Zurich branch of Bank [B. AG] . The BZSt suspected that the account holder may have concealed his capital assets and the resulting income from the German tax authorities. The ESTV decided to provide administrative assistance to the BZSt and transmitted the identity of the account holder, the authorized signatory, and the account opening documents. Complainant [A.] then filed a complaint with the Federal Administrative Court, which was dismissed.Considerations
The Federal Supreme Court examined whether the BZSt's request for administrative assistance met the requirements of the double taxation agreement. It concluded that the request did not constitute an impermissible "fishing expedition". Although the account holder was identified solely by the account number, which is generally permissible under the case law of the Federal Supreme Court, as this is an individual request within the framework of a list request, the criteria developed for group requests are to be…