Kernrechtsfrage
Whether the 1996 Swiss-US tax treaty and implementing ordinance apply to a request concerning earlier tax years
Extrahierter Entscheid
The treaty and ordinance apply immediately because their assistance rules are procedural and took effect before the decision.
Extrahierte Begründung
Procedural provisions on information exchange and private disclosure obligations are to be applied from their entry into force, even if the underlying tax years predate them.