Germany–Switzerland tax treaty protocol enters into force, updating cross-border rules and BEPS standards.
The Swiss State Secretariat for International Finance announced that the protocol amending the 1971 income and capital tax treaty with Germany came into force on 27 November 2025.
The protocol, signed on 21 August 2023, updates the treaty to reflect the needs of both states and enhances legal certainty and cooperation, including clarifications on cross-border employment, mutual agreement procedures, and OECD-based attribution of corporate profits to permanent establishments.
It also implements BEPS minimum standards for DTAs, introducing an anti-abuse clause to prevent non-residents from claiming treaty benefits and aligning mutual agreement procedures with international norms.
The protocol applies from 1 January 2026.
Earlier, Germany published the law ratifying the sixth protocol, which amends the 1971 tax treaty with Switzerland on 30 October 2025.
