The tax treaty between the United States and Switzerland was signed in 1996 and an additional protocol was added in 2009. The aim of the agreement is to avoid double taxation of Americans living in Switzerland and Swiss living in the United States, but it does not prevent US citizens living in Switzerland from having to submit US taxes. Bern, 20.09.2019 – On 20 September 2019, Switzerland and the United States of America exchanged in Bern the instruments of ratification of the Protocol of Amendment to their Double Taxation Convention in the field of income taxation (DBA). The protocol, which entered into force on the same day, marks an important milestone in tax relations between Switzerland and the United States. In October 2010, an agreement was signed to start negotiations for an agreement that will tax undeclared british accounts in Switzerland and share more information on tax and banking information between the two states. The agreement will strengthen, inter alia, cross-border cooperation in tax matters and improve banks` access to market access. Negotiations began in early 2011 and the agreement was signed on 6 October 2011. A protocol was signed on 20 March 2012 to clarify the outstanding issues. Protocol Amending the Agreement between the United States of America and the Swiss Confederation for the Avoidance of Double Taxation of Income Tax, signed in Washington on 23 September 2009 and signed in Washington on 23 September 2009, corrected by an amendment adopted on 16 The exchange of notes took place in Washington on 23 November 2010 and an agreement related thereto, which will be concluded on 23 September by exchange of notes, PDF – 2009 The protocol also provides that inheritance will be included in the treaty. Beneficiaries of an undisclosed Swiss bank account must either pay inheritance tax or consent to the disclosure to the UK authorities. This agreement largely follows the OECD Model Agreement and Swiss policy in this regard.
Among other provisions, dividends paid to individual pension funds – Pillar 3a in Switzerland – are exempt from transfer 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 cartel procedure. . . .