Amendments to the double taxation agreement with France in force

Bern, 04.11.2010 - The additional agreement amending the double taxation agreement (DTA) between Switzerland and France entered into force today. As a result, the first agreement in accordance with the OECD standard on administrative assistance in tax matters is now legally binding. The main changes in the revised DTA also include simplified provisions on abuse as well as a provision whereby Switzerland can tax second pillar lump-sum payments to recipients resident in France in future, provided they are not taxed by France. Moreover, pension institutions can now take advantage of the benefits of the agreement.

Today, Switzerland and France informed one another via diplomatic channels, i.e. during a working meeting between State Secretary Peter Maurer and General Secretary Pierre Sellal, that the additional agreement had been approved in both countries in accordance with national law. The additional agreement has entered into force as a result of this exchange of ratification declarations. The provisions of the additional agreement regarding income tax apply to earnings from calendar or financial years that commence on or after 1 January 2011. The administrative assistance provisions will be applicable for calendar or financial years that commence on or after 1 January 2010.The additional agreement was signed in Bern on 27 August, and was approved by parliament on 18 June 2010. The referendum deadline expired unused on 7 October 2010.

Address for enquiries

François Bastian, Division for International Affairs, Federal Tax Administration, tel. 031 322 71 52


Federal Department of Finance