Among the countries that have double taxation agreements with Switzerland are some of the countries that have double taxation agreements with Switzerland: among Switzerland`s double taxation conventions is the treaty signed with France in 1966 and implemented in 1969. In 1998, a new protocol covering withholding tax on dividends, interest, royalties and capital gains was added to the Franco-Swiss double taxation agreement. A new provision on the rules for preventing tax evasion has also been added. The new provision on withholding tax would also clarify the abolition of double taxation against French and Swiss branches and would also allow France to apply its legislation on controlled foreign companies. The double taxation agreement between France and Switzerland was last amended at the end of 2014. The protocol became necessary to appease the European Commission, which had considered that the agreement could be contrary to the European Treaty. By threatening to refer the matter to the European Court of Justice, the United Kingdom and Switzerland have agreed that account holders who have already paid the 35% withholding tax due under the European Savings Tax will be subject to a final withholding tax of 13% in order to reduce the tax debt on interest payments. On 13 March 2009, the Federal Council announced that Switzerland intends to adopt OECD standards for mutual tax assistance, in accordance with Article 26 of the OECD Model Tax Convention. The decision allows the exchange of information with other countries in individual cases where a concrete and reasoned request has been made.
The Federal Council has decided to withdraw the reserve for the OECD`s model tax treaty and to begin negotiations on the revision of double taxation conventions. However, Swiss banking secrecy remains intact. Steps before entry into force The initialization is defined as the approval of a treaty text by adding initials. Negotiators can thus tentatively draft the text of the treaty negotiated by the DBA (and other international agreements). The signed text is first and foremost confidential. The cantons and relevant professional organisations are informed of the content in a brief report and invited to comment. Cantonal experts can also participate in negotiations with countries important to Switzerland. The agreement will not be published until after it is signed.
The Federal Council authorizes the signing of the agreement. The Federal Department of Finance (EFD) will then prepare a message for the Parliament responsible for the approval of the DBA.