Federal Council adopts two dispatches on double taxation agreements with Liechtenstein and Norway

Bern, 28.10.2015 - Today, the Federal Council adopted the dispatch on the new double taxation agreement (DTA) with Liechtenstein and on its implementation in addition to the dispatch on the revision of the DTA with Norway. Both dispatches were submitted to Parliament for approval.

The new DTA signed with Liechtenstein on 10 July 2015 is a comprehensive agreement for the avoidance of double taxation on income and capital. It replaces the current agreement of 22 June 1995 between Switzerland and Liechtenstein which only covers the taxation of certain income. The new DTA governs in particular the taxation of old age and survivors' insurance (AHV) pensions. These can be taxed solely in the state of residence, and the DTA will eliminate the current double taxation of AHV pensions from Liechtenstein for people who live in Switzerland. For cross-border commuters, the respective state of residence will continue to retain the right of taxation. The taxation of dividends, interest and royalty payments is now also governed by the DTA. The DTA contains solutions for this income which are comparable to those recently concluded by Switzerland in other agreements.

On 4 September 2015, Switzerland and Norway signed a protocol of amendment in Oslo to their DTA in the area of taxes on income and capital. The most favoured nation clause will be implemented with this protocol of amendment. The new arbitration clause ensures that double taxation will be avoided. In addition, Article 26 on the exchange of information was amended at Norway's request.

The cantons and business associations concerned have welcomed both agreements. Switzerland has concluded 52 double taxation agreements overall that are in line with the international standard on the exchange of information; 41 of these are in force.