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Double Tax Treaties in Switzerland
By Markus Pritzker, off-counsel
Published: 01.04.2021, updated: 11.03.2025
Featuring one of the world's most stable and secure economies, Switzerland's government wanted to make taxation as simple as possible for foreign investors, so the country signed over 80 treaties with nations worldwide to prevent double taxation.
Over the last few decades and earlier, a number of tax treaties have been signed with numerous countries around the world. Some of these countries include Australia, the US, Ireland, India, and Germany.
The treaties were designed and modelled after the OECD organisation. In 2009, Switzerland chose to implement the OECD model into the country, with the final decision to do so resting on the Federal Council. Following this, all existing treaties with other nations were adapted to suit the new model, Article 26 of the OECD Model Convention. The main feature of the new treaty was that regulations of withholding tax, capital tax, and income tax may be reduced depending on the residency of the shareholders.
Income tax is regulated in Switzerland, allowing it to be withheld and refunded if the Swiss tax administration is consulted. Additionally, if the income has already been taxed in one of the 80 treaty nations, it is exempt from Swiss tax.
Information sharing between Swiss and foreign regulators is assured as part of the double tax treaty. Utilising this information allows other nations and Switzerland to prevent tax fraud and other fraudulent behaviours.
It is important to note that banking security and secrecy from Swiss banks remain, even with the nations who signed the treaties.
Taxation on withholding dividends, interests and royalties are reduced for companies with foreign capital; in some circumstances, taxes can be exempt.
Our website provides more information about Swiss taxation and company formation. For further assistance, contact one of our consultants.
Over the last few decades and earlier, a number of tax treaties have been signed with numerous countries around the world. Some of these countries include Australia, the US, Ireland, India, and Germany.
The treaties were designed and modelled after the OECD organisation. In 2009, Switzerland chose to implement the OECD model into the country, with the final decision to do so resting on the Federal Council. Following this, all existing treaties with other nations were adapted to suit the new model, Article 26 of the OECD Model Convention. The main feature of the new treaty was that regulations of withholding tax, capital tax, and income tax may be reduced depending on the residency of the shareholders.
Income tax is regulated in Switzerland, allowing it to be withheld and refunded if the Swiss tax administration is consulted. Additionally, if the income has already been taxed in one of the 80 treaty nations, it is exempt from Swiss tax.
Information sharing between Swiss and foreign regulators is assured as part of the double tax treaty. Utilising this information allows other nations and Switzerland to prevent tax fraud and other fraudulent behaviours.
It is important to note that banking security and secrecy from Swiss banks remain, even with the nations who signed the treaties.
Taxation on withholding dividends, interests and royalties are reduced for companies with foreign capital; in some circumstances, taxes can be exempt.
Our website provides more information about Swiss taxation and company formation. For further assistance, contact one of our consultants.