A further obstacle to making the company non-resident was presented by s.251. Denmark was the other country chosen. The board would meet in the United Kingdom but management of the day to day business was moved to Denmark. Swiss Bank Secrecy - Joseph Field Article 47 of the Federal Banking Law makes divulgence of secrets a criminal offence. It is also a breach of a banker's civil duty to his client.
Swiss law protects secrecy in other ways also.
Switzerland is anxious to co-operate with other nations in fighting crime, though tax evasion is not a crime in Switzerland. The Marcos case may indicate that the Swiss government has embarked on a new policy. The Swiss court has been willing to allow information to be exchanged under a tax treaty, but only where tax fraud is shown. In the Mark Rich case, the US court took jurisdiction over the Swiss company, but the Swiss court refused to order the company to reveal information. Agreement XVI may be of limited value only.