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Germany and Switzerland Extend Amendments to Mutual Agreement on Arbitration Under Tax Treaty

03 April 2025

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Treaty Development

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Germany-Switzerland

On 28 March 2025, the German Ministry of Finance published an agreement with Switzerland that permanently extends amendments agreed to in 2019 to the 2016 mutual agreement on the application of arbitration procedures under the 1971 tax treaty between the two countries. The amendments introduced a provision that a case may not be submitted for arbitration in the event a taxpayer provided incorrect information or failed to submit correct (accurate) information in one or both Contract States during an assessment or mutual agreement procedure in order to obtain beneficial tax treatment under the treaty. The latest agreement was signed by...