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Swiss National Council Approves Pending Protocols to Tax Treaties with Germany and Hungary

11 March 2025

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Treaty Development

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Switzerland-Germany-Hungary

On 5 March 2025, the Swiss National Council (lower house of parliament) approved the ratification of the pending protocols to the income and capital tax treaties with Germany and Hungary. Among other things, both protocols include updates in line with BEPS standards, as well as additional provisions to clarify the applicability of national minimum taxation rules in accordance with the Pillar 2 GloBE Rules. The protocol to the tax treaty with Germany was signed on 21 August 2023 and is the sixth to amend the treaty. It will enter into force once the ratification instruments are exchanged and will generally...