The Swiss parliament granted final approval to the amending protocol to the 1971 income and capital tax treaty with Germany on 21 March 2025.
The protocol complies with BEPS standards and introduces additional provisions to clarify how national minimum taxation rules apply under the Pillar Two GloBE Rules.
It will come into effect once the ratification instruments are exchanged and will be applicable from 1 January of the year after its entry into force.
Earlier, the Swiss National Council (Nationalrat) approved the ratification of the amending protocol with Germany on 5 March 2025. The protocol was signed on 21 August 2023.