The German Ministry of Finance announced a new agreement on 28 March 2025 with Switzerland that permanently extends the 2019 amendments to the 2016 mutual agreement concerning arbitration procedures under the 1971 tax treaty between the two nations.
A change first introduced in 2019 stated that a tax dispute cannot be taken to arbitration if a taxpayer provided false or incomplete information during a tax assessment or a mutual agreement process in either country to gain favourable tax treatment.
The new agreement, signed by Switzerland on 18 March 2025 and by Germany on 24 March 2025, confirms that this condition will now remain in place indefinitely. It will only end if one of the countries formally withdraws it through their respective tax authorities.
Earlier, the Swiss parliament granted final approval to the amending protocol to the 1971 income and capital tax treaty with Germany on 21 March 2025.
