Initialling of DTA between Switzerland and Germany on the fringes of the meeting between Finance Ministers Merz and Schäuble
Bern, 26.03.2010 - Today, Federal Councillor Hans-Rudolf Merz and the German Finance Minister, Wolfgang Schäuble, discussed bilateral tax issues in an open and constructive manner during a working meeting in Berlin. The focus of the talks was on the initialling of the Protocol of Amendment to the existing double taxation agreement (DTA) between Switzerland and Germany. The issue of the use of purchased bank client data by the German tax authorities was also broached. The two ministers have mandated a bilateral working group to clarify unresolved financial and tax issues for the signing of the DTA.
Today in Berlin, the Protocol of Amendment to the existing double taxation agreement (DTA) between Switzerland and Germany was initialled on the fringes of the meeting between Federal Councillor Hans-Rudolf Merz and Finance Minister Wolfgang Schäuble. The extension of administrative assistance in tax matters in accordance with the OECD standard is the key element of the revision of the DTA. The administrative assistance clause is in line with the key points agreed by the Federal Council. The agreement with Germany is the twenty-third with an administrative assistance clause in accordance with Art. 26 of the OECD Model Convention. Along with extending administrative assistance in tax matters, Switzerland has also been able to negotiate various benefits for the country as a business location. The text of the DTA will be published when it is signed.
Bilateral working group for clarifying unresolved financial and tax issues
To further clarify the unresolved financial and tax issues in a constructive manner, Federal Councillor Merz and Finance Minister Schäuble have appointed a joint working group led by their respective State Secretaries. The working group's brief includes clarifying the following matters in particular:
- Possibilities for arranging the taxation of German residents' untaxed assets that are invested in Swiss financial institutions;
- Ensuring the taxation – in the form of a final withholding tax – of the ongoing investment income from assets that are invested in Swiss financial institutions by German residents, as well as the transfer of such assets, particularly by way of inheritance or endowment;
- Market access; based on the solutions proposed by the relevant supervisory authorities, examining extended market access for Swiss banks in Germany;
- Accompanying work associated with the signature of the Protocol of Amendment to the bilateral double taxation agreement, including matters regarding the handling of the purchase of bank data and comprehensive information for Switzerland on this issue.
Regarding the purchased bank data, Germany has acknowledged that Switzerland will not provide administrative assistance on the basis of purchased bank data.
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Federal Department of Finance
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