By Davide Anghileri, University of Lausanne
Switzerland’s Federal Council, during its meeting on 4 November, agreed to significant amendments to the laws relating to tax treaties. The new legislation would apply provided the applicable tax treaty does not contain any deviating provisions.
The dispatch on the Federal Act on the Implementation of International Tax Agreements, approved by the Council, aims to adapt Swiss law to the changes made to international tax law in recent years.
The project intends to completely amend the Federal Act of 1951 on the Implementation of International Federal Conventions on the Avoidance of Double Taxation so as to ensure that tax agreements can continue to be applied easily and with legal certainty in the future.
The new law would stipulate how mutual agreement procedures in tax treaties are to be carried out at the national level.
Moreover, the new law contains the key points on withholding tax relief based on international agreements, as well as criminal provisions in connection with relief from withholding taxes on capital income.
Hence, the Federal Council is proposing to supplement the existing standards with additional regulation.
The Swiss Parliament is due to discuss the reform for the first time in the first half of 2021.
Davide Anghileri
Davide Anghileri is a PhD candidate at the University of Lausanne, where he is writing his thesis on the attribution of profits to PEs. He researches transfer pricing issues and lectures for the Master of Advanced Studies in International Taxation and Executive Program on Transfer Pricing.
Anghileri, a Contributing Editor at MNE Tax, previously worked as a policy advisor to the Swiss government on BEPS issues.
Davide can be reached at [email protected].
Latest posts by Davide Anghileri (see all)
- Swiss government approves new law governing tax treaties - November 11, 2020
- EU states’ compliance with tax avoidance directives assessed in Commission report - August 26, 2020
- Italy clarifies VAT reporting obligations of online marketplaces - June 16, 2020
- EU blacklist: Cayman Islands added with other three jurisdictions - February 18, 2020
- Italy adopts digital services tax, notional interest deduction - January 8, 2020
Be the first to comment