Switzerland on November 19 signed a multilateral competent authority agreement, moving the country one step closer to adopting automatic exchange of financial account information under the OECD/G-20 Common Reporting Standard beginning 2018 . . .
A revised tax treaty and protocol between Australia and Switzerland, signed July 30, 2013, entered into force on October 14 , Australia’s tax authority has announced. Australian legislation enforcing the revised tax treaty received royal assent on September 24. See, release, Australia-Switzerland Tax Treaty (142 KB).
WTAS, a firm founded 12 years ago by members of now-defunct accounting firm Arthur Andersen, has renamed itself Andersen Tax. Andersen Tax will be a member of a newly created international entity called Andersen Global.
The firm has 17 offices in the US and locations in Switzerland, Russia, France, Italy, and The Netherlands. Release
Switzerland’s Federal Council on September 11 proposed to extend the temporary withholding tax exemption for interest paid on contingent convertible bonds (CoCos) and write-off bonds of systematically important banks and to establish a similar . . .
Switzerland’s Federal Council announced June 24 that it will no longer pursue reforming the withholding tax system applicable to bond interest switching from the debtor principle to the paying agent . . .
The EU and Liechtenstein on October 28 agreed to automatically exchange tax information on the financial accounts of each other’s residents beginning . . .
Switzerland’s Federal Department of Finance on May 21 announced that Switzerland and Grenada have signed a tax information exchange agreement (TIEA). The agreement, signed . . .
Switzerland and the European Union on March 19 initialed an agreement to commence automatic exchange of information from 2018 once the necessary legal basis has been created, Switzerland’s Federal Department of Finance has . . .
Switzerland and Australia have signed a joint declaration expressing their intent to begin automatically exchanging information on tax matters using internationally agreed standards beginning in 2018, the Swiss government announced March 3. Collection of the data will begin in 2017. The agreement, signed in Canberra, is the first declaration on automatic exchange of information. . .
Switzerland’s Federal Council on October 15 adopted a dispatch on the double taxation agreement with Argentina and submitted the agreement to parliament for approval. Release.
Switzerland’s Federal Council on October 28 announced it has approved a new tax treaty with Liechtenstein and a tax treaty protocol with Norway . . .
Switzerland and Oman on May 22 signed a double taxation agreement, Switzerland’s Federal Department of Finance has announced. The agreement sets the tax rate on dividends in the source country at 5 percent . . .
In a surprising development, the US Senate Committee on Foreign Relations on November 10 approved without amendment proposed income tax treaties with Chile, Hungary, and Poland; proposed tax protocols with Japan, Luxembourg, Spain, and Switzerland; and a proposed protocol amending the multilateral mutual administrative assistance treaty. . .
Switzerland’s Federal Department of Finance on November 14 announced that the ratification procedures for new double tax treaties with Australia, Hungary, and China have been concluded and all three treaties have entered into force. The new treaties with Australia and Hungary entered into force . . .
The Swiss government on November 24 announced that double tax agreements signed by Switzerland and Cyprus, Iceland, Estonia, and Uzbekistan have entered into force. The goverment also announced that Switzerland signed . . .
Witnesses testifying before the US Senate Committee on Foreign Relations on October 29 urged the committee to recommend ratification of eight pending US tax treaties and protocols, highlighting key aspects of the . . .
Switzerland and Norway have signed protocol to amend their 1987 double taxation agreement to introduce an arbitration . . .
The Isle of Man Treasury announced on October 21 that the “Agreement for the Exchange of Information Relating to Tax Matters” signed by the Isle of Man and Switzerland on August 28, 2013, entered into force on October 14. Release.
Switzerland and Albania on September 9 signed a protocol to amend their November 1999 double taxation . . .
The European Union and Switzerland on May 27 signed an agreement to commence automatic exchange of bank account information from 2018. Switzerland also launched a consultation
. . .
taly and Switzerland on February 23 signed a protocol to their double tax treaty agreeing to the OECD standard for the exchange of information on request, the Swiss government has announced. The countries also signed a roadmap for continued dialog on financial and tax matters . . .
Switzerland’s Federal Council, on April 22, announced that it has instructed the Federal Department of Finance to create the legal basis for rules that would provide a flat-rate tax credit for foreign companies’ permanent establishments in Switzerland which have their registered office in a country with which Switzerland has a double taxation agreement. The credit would alleviate double . . .
The Swiss Federal Council on November 28 issued a dispatch discussing proposed changes to the taxation of residents and nonresidents currently subject to withholding tax on earned income. See, release.
Tax information exchange agreements (TIEAs) between Switzerland and Andorra, Greenland, San Marino, and the Seychelles have been ratified and came into force in July and August, Switzerland’s Federal Department of Finance announced on September 9. All the . . .
Switzerland’s Federal Council on August 26 announced that it will recommend that Parliament reject a move to heighten bank client confidentiality through the “Yes to the protection of privacy” initiative . . .
The Swiss Federal Counsel on October 22 launched a consultation on a proposed law that would . . .
Switzerland and Iceland, on July 10, signed a double taxation agreement which includes exchange of information provisions and an arbitration clause. The agreement replaces a 1988 double tax agreement. Under the new agreement, royalties are subject to no more than 5 percent tax in the source state. The parties agreed to a withholding tax exemption for divided payments from significant holdings of at least 10 percent and for divided payments to pension funds and national banks. The agreement specifies that pension contributions in the other country are deductible. For more details, see press release.
The Swiss government is working with business groups to craft rules to replace its cantonal corporate tax system, writes SWI swissinfo.ch, the international service of the Swiss Broadcasting Corporation, in a August 20 article. See: SWI swissinfo.ch
Switzerland and Liechtenstein have agreed to the terms of a revised double tax treaty and expect to sign the agreement this summer, Switzerland’s Federal Department of Finance (FDF) announced on February 5. The agreement, which would replace . . .
Citing OECD pressure to reform its tax system, Switzerland is considering abolishing existing tax arrangements that no longer meet international tax standards, primarily the cantonal tax statuses for holding, domiciliary, and mixed companies. New rules would be added, however, to enhance the country’s “appeal as a tax location,” including a royalty box and. . .
Switzerland and Estonia, on August 25, signed a protocol to amend their double taxation agreement.
Under the agreement, interest and royalty payments are exempt from withholding tax. Dividends are also exempt from withholding tax if the company receiving the dividend holds a stake of at least 10 percent in the capital of the distributing company for at least one year. In other cases, the withholding tax rate for dividend distributions is 10 percent.
The agreement also provides for the exchange of information upon request in accordance with the currently applicable international standard.
The agreement must be approved by parliament in both countries before it can come into force. Release
The Swiss Federal Council, on August 20, approved tax information exchange agreements with Andorra, Greenland, San Marino, and the Seychelles. The agreements will be submitted to parliament for approval. press release
Switzerland’s Federal Council on April 29 initiated a consultation on a federal decree which would implement automatic exchange of information in tax matters with Australia. The consultation follows up on a joint declaration . . .
Switzerland’s Federal Council on Sept. 9 adopted report on the tax treatment of fines including fines that arise in an international context. The report concludes that fines, including tax penalties and financial administrate sanctions, are putative in nature and therefore can not be deducted. Profit disgorgement sanctions, on the other hand, which require repayment of taxable profits obtained by illegal acts, can be deducted. For more details, see release, report (in German).
The Switzerland and Italy have reached an agreement in principle to sign a protocol to their double tax treaty to make provision for the OECD standard for the exchange of tax information upon request, the Swiss government announced January 16. The countries have also initialed a roadmap . . .
Switzerland’s Federal Council on October 8 released final negotiation mandates for introducing automatic exchange of information in tax matters with the EU, the United States, and other countries . . .
The Swiss Federal Council on Sept. 19 initiated a consultation on rules that would extend the flat-rate credit to permanent establishments in Switzerland that are domiciled in a country that has a direct tax agreement (DTA) with Switzerland. . .
The magnitude of profit shifting by American companies “may be significant,” a US Congressional Research Service (CRS) report has concluded. The report, released April 30, found that about 50 percent of the $1.2 trillion in overseas profit reported by American . . .
The Swiss Federal Council on December 17 submitted for consultation a bill proposing to replace its current debtor system of withholding to a system based on a paying agent principle. The consultation will run until March 31, 2015. See, release.
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