Switzerland’s Council of States approved protocols amending income and capital tax treaties with Germany and Serbia on 9 December 2024.
Earlier, the Swiss Federal Council announced that it had adopted the dispatch on the protocol of amendment to the double taxation agreement (DTA) with Germany on 14 June 2024. The protocol adapts the DTA to various changes in the needs of the contracting states and implements the minimum standards from the base erosion and profit shifting (BEPS) project regarding DTAs. Signed on 21 August, 2023, the protocol marks the sixth amendment to the tax treaty. It incorporates updates consistent with BEPS standards and introduces provisions to clarify the implementations of forthcoming national minimum taxation rules in alignment with the Pillar Two global minimum tax (GloBE) rules.
The Swiss National Council (lower house of parliament) approved the ratification of the protocol to the 2005 tax treaty with Serbia on 25 September 2024. The protocol, which was originally signed on 19 September 2023, is the first amendment to the treaty. It will enter into force once the ratification instruments are exchanged and will apply from 1 January of the year following its entry into force.
