Kernrechtsfrage
Whether the account holder's identity had to be withheld from Canadian authorities
Extrahierter Entscheid
No. The identity of C. could be disclosed because the request concerned a Canadian criminal investigation, not a fiscal proceeding, and the speciality reservation barred use for tax matters or disclosure to third states.
Extrahierte Begründung
C. was objectively linked to the investigated transfers and had opened and signed the account documents. The court held that Switzerland could not impose a restriction incompatible with its treaty obligations; any concern about onward transmission to the US had to be raised with Canadian authorities, and trust principles applied.