Amendments to the double taxation agreement with Germany enter into force

Bern, 21.12.2011 - The revised double taxation agreement (DTA) between Switzerland and Germany has entered into force with today's exchange of the instruments of ratification. The DTA contains provisions on the exchange of information in accordance with the international standard applicable at present, and will contribute to the further positive development of bilateral economic relations. The ratification process also includes the agreement with Germany on a withholding tax levied at source.

The revision of the existing DTA with Germany was signed on 27 October 2010 and subsequently approved by parliament in both countries. Today in Berlin, the instruments of ratification were exchanged by the Swiss Ambassador, Tim Guldimann, and Franz Josef Kremp, from Germany's Foreign Office. The DTA thus entered into force on the same day in compliance with the text of the agreement.

The revised agreement contains an administrative assistance clause on the exchange of information in accordance with the internationally applicable standard. In addition, the new DTA contains various provisions that are beneficial to the economies of Switzerland and Germany. For example, the stake required for the zero rate of tax on dividends will be reduced and an arbitration clause introduced.

The agreement's provisions on the exchange of information will apply from 1 January 2011, and the remaining provisions will apply from 1 January 2012.

The agreement already signed by Switzerland and Germany on an international withholding tax levied at source is still in the process of being ratified. It should be submitted to parliament for approval in both countries in 2012 and enter into force in 2013.

Address for enquiries

Mario Tuor
Communications, State Secretariat for International Financial Matters SIF
+41 31 322 46 16


Federal Department of Finance