Global

Details

  • Service: Tax, International Corporate Tax, International Executive Services, Global Compliance Management Services
  • Type: Regulatory update
  • Date: 3/22/2013

Switzerland - Distinctive tax treaty with Germany 

March 22: The income tax treaty between Switzerland and Germany and the corresponding Switzerland-Germany estate and inheritance tax treaty contain distinctive provisions that taxpayers need to consider in their cross-border dealings.

For example, knowledge about certain treaty provisions (including the following) may be critical.


  • Specifics in respect of dual residence and permanent home—overriding and competing taxation
  • Modified lump-sum taxation
  • Specifics for companies / dual resident in two countries
  • Partnerships
  • Cross-border commuters, senior executives
  • Specifics for governing board members
  • Anti-abuse provision
  • Specifics in the so-called “method” article (e.g. activity restriction)
  • New arbitration clause
  • Developments on exchange of information and group enquiries

Read a 2013 report prepared by the KPMG member firm in Switzerland: One of a kind – the Double Taxation Agreement between Germany and Switzerland




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KPMG International is a Swiss cooperative that serves as a coordinating entity for a network of independent member firms. KPMG International provides no audit or other client services. Such services are provided solely by member firms in their respective geographic areas. KPMG International and its member firms are legally distinct and separate entities. They are not and nothing contained herein shall be construed to place these entities in the relationship of parents, subsidiaries, agents, partners, or joint venturers. No member firm has any authority (actual, apparent, implied or otherwise) to obligate or bind KPMG International or any member firm in any manner whatsoever.


The information contained in herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation.


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For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at:

+ 1 202 533 4366

1801 K Street NW
Washington, DC 20006.

 

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