A pact has just been agreed between the two countries which should enable Switzerland's 300 banks to clear up outstanding enquiries with the US within a couple of years. The Swiss Bankers Association is quoted in Bloomberg Law as saying: 'The program enables all banks in Switzerland to settle their U.S. past quickly and conclusively and creates the necessary legal certainty.'

Milan Patel, a partner in Anaford AG who used to be a tax lawyer in the US, says: 'The Swiss have finally decided to deal with the issue of creating an exception to Swiss bank secrecy by employing an administrative procedure to avoid legal challenges and a public referendum, which could otherwise defeat any settlement.'