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Tax deal Switzerland-USA - "The way it is now, it pays off for everyone"

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Something seems to be going on in the double taxation agreement between Switzerland and the USA. The revision has been blocked for eight years, now the Senate committee has said yes. But why does this agreement even work? Martin Naville explains the importance of the agreement in an interview.

SRF News: What is the double taxation agreement about?

Martin Naville: In general, the DTA is an agreement to prevent double taxation. That a company or a person does not have to pay taxes in Switzerland and America at the same time.

In the meantime, Switzerland has the automatic exchange of information with the USA, the so-called Fatca Agreement. Is the DBA still needed at all?

Of course it is needed because double taxation goes much further than the Fatca Agreement or the automatic exchange of information according to the OECD. The double taxation treaty concerns much more than just the exchange of information.

Which taxes are affected by this double taxation agreement?

The income tax of individuals and companies. The exchange of information only regulates the information per se and not the tax liability. The double taxation agreement is needed so that tax liability does not arise excessively twice.

There are still a few issues that urgently need to be negotiated further.

Can one say that, in contrast to the situation in 2009, when the tax dispute between the USA and Switzerland was still going on, the practical significance of the revised DTA is now significantly less from a Swiss point of view?

The change that was made then is less important now than it was then, as the information now flows much more freely. But there are some issues that urgently need to be negotiated further. One thing is the zero rate. So when a company pays dividends from America to Switzerland and no additional taxes are incurred in the end. The so-called natural resource for withholding tax or double taxation for inheritances must be regulated. All of this can only be negotiated on the basis of a revised and ratified DTA.

Can you give a practical example of who the revised DBA would be worthwhile for?

As it is now, it is worthwhile for everyone. It's not the first DBA with America. One has been in existence since 1996, but it is not sufficient in many technical details. Imagine an American professor at ETH Zurich who receives his salary in Switzerland and pays his taxes in Switzerland. As an American citizen, however, he would also be taxable in America and would have to pay tax on all his income in America at the same time. The DTA regulates which country between Switzerland and America can access taxation. The same applies to companies.

The interview was conducted by Noƫmi Ackermann.

srf / hosb; from

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  • Comment from antigone kunz (antigonekunz)
    With regard to tax evaders, who transfer their money, their values, whatever all these clunkers are called and store them here and there via winding channels, it should apply that they control where they come from, where they have their center of life and where they live are also likely to be citizens of. Or is that too complicated?
    Agree agree to the comment
    1. answer from Hans Ochsner (Hans Ochsner)
      What does this have to do with the subject of double taxation agreements?
      Agree agree to the comment
    2. answer from Jean-Philippe Ducrey (Jean-Philippe Ducrey)
      @Kunz: Basically every state says that its citizen must also be its taxpayer. However, the state of the center of life also wants to garnish taxes. In this respect, corresponding agreements have been developed so that people who work abroad (e.g. Swiss scientists in the USA) do not have any disadvantages. That is why these agreements exist. In connection with Switzerland, there is also a special focus on taxes on capital gains that foreigners deposit with Swiss banks.
      Agree agree to the comment
    3. Show answers
  • Commentary by Jean-Philippe Ducrey (Jean-Philippe Ducrey)
    Additions: 1. The FACTA is a one-sided thing, i.e. the USA receives information from Switzerland, but Switzerland does not receive information from the USA. 2. In accordance with the 1996 agreement, income is only taxed where it is generated. But not the fortune. In the case of two residences (CH-USA), this may have to be taxed at both residences (if the US state has a wealth tax). 3. The new DBA does not provide for any changes in these points.
    Agree agree to the comment

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