Switzerland Tax Agency Announces Consultation Agreement Extension Regarding Application of 1971 DTA, Protocols With Germany

The Swiss Federal Tax Administration Oct. 16 announced that the competent authorities of Switzerland and Germany agreed to extend the consultation agreement, signed April 6, 2023, on the application of the 1971 Germany-Switzerland DTA, last amended in 2010, concerning senior executives. The announcement includes an application extension of Article 15(4) of the DTA to: 1) persons who are registered in the Swiss Commercial Register, either with a single signature or collective signature, without designation of their function; and 2) persons not registered in the commercial register holding a position within a corporation that, with respect to associated management and representation ...