(September 10, 2015)

On September 9, 2015 the Swiss Federal Department of Finance (FDF) issued a press release announcing that the tax information exchange agreements (TIEAs) with Andorra, Greenland, San Marino and Seychelles entered into force.

 

According to the announcement, TIEAs entered into force on the following dates:

·         Switzerland – San Marino TIEA on July 20, 2015;

·         Switzerland – Greenland TIEA on July 22, 2015;

·         Switzerland – Andorra TIEA on July 27, 2015;

·         Switzerland – Seychelles on August 10, 2015.

 

Below we will discuss a selection of regulations included in the TIEAs of which we think they might interest our readers.

 

San Marino

 

The TIEA arranges for the Exchange of Information Upon Request (Article 5 of the TIEA).

 

Based on Article 3, paragraph 1 of the TIEA (“Taxes Covered”) the taxes which are the subject of the TIEA are:

a)      in Switzerland,

i)       the federal, cantonal and communal taxes on income (total income, earned income, income from capital, industrial and commercial profits, capital gains, and other items of income);

ii)      the federal, cantonal and communal taxes on capital;

iii)    the cantonal and communal inheritance and gift taxes;

b)      in San Marino,

the general income tax which is levied:

i)       on individuals;

ii)      on bodies corporate and proprietorships;

even if collected through a withholding tax.

 

Based on Article 3, paragraph 2, the Agreement shall apply to any identical taxes imposed after the date of signature of the Agreement in addition to or in place of the existing taxes. The Agreement shall also apply to any substantially similar taxes imposed after the date of signature of the Agreement in addition to or in place of the existing taxes if the competent authorities of the Contracting Parties so agree.

 

Based on the information as provided by the Swiss Federal Department of Finance (FDF) (that the TIEA entered into force on July 20, 2015), according to Article 11, Paragraph 3 of the Agreement the provisions of the Agreement shall have effect for requests made on or after the date of entry into force of the Agreement for information that relates to any taxable period beginning on or after January 1, 2016 or, where there is no taxable period, for all charges to tax arising on or January 1, 2016.

 

For further information click here to be forwarded to the text of the Agreement between the Swiss Confederation and the Republic of San Marino for the Exchange of Information on Tax Matters as available on the website of the Swiss Federal Department of Finance (FDF).

 

Greenland

 

The TIEA arranges for the Exchange of Information Upon Request (Article 5 of the TIEA).

 

Based on Article 3, paragraph 1 of the TIEA (“Taxes Covered”) the taxes which are the subject of the TIEA are taxes of every kind and description imposed in the Contracting Parties.

 

Based on Article 3, paragraph 2, the Agreement shall apply to any taxes imposed after the date of signature of the Agreement in addition to or in place of the existing taxes.

 

Based on the information as provided by the Swiss Federal Department of Finance (FDF) (that the TIEA entered into force on July 22, 2015), according to Article 11, Paragraph 3 of the Agreement the provisions of the Agreement shall have effect for requests made on or after the date of entry into force of the Agreement for information that relates to any taxable period beginning on or after January 1, 2016 or, where there is no taxable period, for all charges to tax arising on or after January 1, 2016.

 

For further information click here to be forwarded to the text of the Agreement between the Swiss Confederation and Greenland for the Exchange of Information on Tax Matters as available on the website of the Swiss Federal Department of Finance (FDF).

 

Andorra

 

The TIEA arranges for the Exchange of Information Upon Request (Article 5 of the TIEA).

 

Based on Article 3, paragraph 1 of the TIEA (“Taxes Covered”) the taxes which are the subject of the TIEA are:

a)      in Switzerland,

i)        the federal, cantonal and communal taxes on income (total income, earned income, income from capital, industrial and commercial profits, capital gains, and other items of income);

ii)       the federal, cantonal and communal taxes on capital;

iii)     the cantonal and communal inheritance and gift taxes;

b)      Andorra,

i)        the corporation tax;

ii)       the tax on income from economic activities;

iii)     the tax on income for fiscal non-residents;

iv)     the tax payable on the increase in value in immovable property transfers.

 

Based on Article 3, paragraph 2, the Agreement shall apply to any identical taxes imposed after the date of signature of the Agreement in addition to or in place of the existing taxes. The Agreement shall also apply to any substantially similar taxes imposed after the date of signature of the Agreement in addition to or in place of the existing taxes if the competent authorities of the Contracting Parties so agree.

 

Based on the information as provided by the Swiss Federal Department of Finance (FDF) (that the TIEA entered into force on July 27, 2015), according to Article 11, Paragraph 3 of the Agreement the provisions of the Agreement shall have effect for requests made on or after the date of entry into force of the Agreement for information that relates to any taxable period beginning on or after January 1, 2016 or, where there is no taxable period, for all charges to tax arising on or after January 1, 2016. 

 

For further information click here to be forwarded to the text of the Agreement between the Swiss Confederation and the Principality of Andorra for the Exchange of Information on Tax Matters as available on the website of the Swiss Federal Department of Finance (FDF).

 

Seychelles

 

The TIEA arranges for the Exchange of Information Upon Request (Article 5 of the TIEA).

 

Based on Article 3, paragraph 1 of the TIEA (“Taxes Covered”) the taxes which are the subject of the TIEA are:

a)      in Switzerland,

i)       the federal, cantonal and communal taxes on income (total income, earned income, income from capital, industrial and commercial profits, capital gains, and other items of income);

ii)      the federal, cantonal and communal taxes on capital;

iii)    the cantonal and communal inheritance and gift taxes;

b)      in Seychelles,

i)       the business tax.

 

Based on Article 3, paragraph 2, the Agreement shall apply to any identical taxes imposed after the date of signature of the Agreement in addition to or in place of the existing taxes. The Agreement shall also apply to any substantially similar taxes imposed after the date of signature of the Agreement in addition to or in place of the existing taxes if the competent authorities of the Contracting Parties so agree.

 

Based on the information as provided by the Swiss Federal Department of Finance (FDF) (that the TIEA entered into force on August 10, 2015), according to Article 11, Paragraph 3 of the Agreement the provisions of the Agreement shall have effect for requests made on or after the date of entry into force of the Agreement for information that relates to any taxable period beginning on or after January 1, 2016 or, where there is no taxable period, for all charges to tax arising on or after January 1, 2016.

 

For further information click here to be forwarded to the text of the Agreement between the Swiss Confederation and the Republic of Seychelles for the Exchange of Information on Tax Matters as available on the website of the Swiss Federal Department of Finance (FDF).

 

 

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