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On 13 March 2009, the Federal Council announced that Switzerland intends to adopt OECD standards for mutual tax assistance, in accordance with Article 26 of the OECD Model Tax Convention. The decision allows the exchange of information with other countries in individual cases where a concrete and reasoned request has been made. The Federal Council has decided to withdraw the reserve for the OECD`s model tax treaty and to begin negotiations on the revision of double taxation conventions. However, Swiss banking secrecy remains intact. While the agreement allows the Social Security administration to qualify for U.S. pension, disability or survival benefits, the agreement does not cover Medicare benefits. Switzerland has signed more than 80 double taxation agreements with countries around the world. Therefore, it is important to consult double taxation agreements before investing in any type of business in Switzerland or opening a business in Switzerland. The Federal Council`s decision is implemented within the framework of bilateral double taxation agreements. Greater information exchange will only have a practical effect if the renegotiated agreements come into force. In addition, adjustments must be made to the agreement with the EU on the taxation of savings. The protocol became necessary to appease the European Commission, which had considered that the agreement could be contrary to the European Treaty.

By threatening to refer the matter to the European Court of Justice, the United Kingdom and Switzerland have agreed that account holders who have already paid the 35% withholding tax due under the European Savings Tax will be subject to a final withholding tax of 13% in order to reduce the tax debt on interest payments. Withholding tax – maximum withholding tax rates are subject to anti-abuse rules for certain types of capital income in U.S. tax treaties and in agreements with other countries. Statistics from January to July 2010 show that imports from Switzerland amounted to 72 million euros (mainly pharmaceuticals, 91.2 million euros in the same period in 2009, while Malta`s exports increased to 9.3 million euros (mainly machinery and pharmaceuticals) compared to 5.7 million euros in the first half of 2009. The agreement will enter into force after ratification by both countries. The protocol [PDF 1.05 MB] amending the swiss-US income tax agreement was signed in September 2009. The protocol provides that a bilateral agreement between the United States and Switzerland improves the protection of social security for people who work or have worked in both countries. It helps people who, in the absence of the agreement, would not be entitled to pension, disability or survival benefits under the social security system of one or both countries. It also helps many people who would otherwise have to pay social security contributions to the two countries with the same incomes. The other provisions are as follows: dividends paid to individual pension funds – in Switzerland, Pillar 3a – are exempt from withholding tax from 1 January 2020. A mandatory arbitration clause ensures that double taxation is avoided even if the competent authorities fail to reach an agreement in the mutual agreement procedure.

There are ways for American expats to avoid a lot of double taxation. There is a treaty between Switzerland and the United States that outlines some of these benefits.