Swiss Eu Savings Tax Agreement 2004

OJ L 385, 29.12.2004, pp. 30-49 (ES, CS, DA, DE, ET, EL, EN, FR, IT, LV, LT, HU, NL, PL, PT, SK, SL, FI, SV) OJ L 347, 31.12.2004, p. 1. OJ L 153M, 7.6.2006, pp. 383-402 (MT)Special edition in Bulgarian: Chapter 09, volume 002 p. 160 – 179 Special edition in Romanian: Chapter 09 Volume 002 p. 160 – 179 Special edition in Croatian: Chapter 09 Volume 001 p. 100 – 112 The Agreement shall apply from 1 May 2004 to all EU Member States, including candidate countries for EU membership. It also applies to Guadeloupe, French Guiana, Martinique, Réunion (France), Gibraltar (United Kingdom), Madeira, the Azores (Portugal) and the Canary Islands (Spain). However, it does not apply to the Channel Islands (Guernsey and Jersey) or the Isle of Man.

The agreement is extended to other territories that join the European Union. Spain and Estonia are subject to temporary arrangements. By its directives of 15 July 2005, the Federal Tax Administration clarified the application of the rules to Swiss dividends from the country. The list of associated entities set out in Annex II may be amended by mutual agreement. The agreement obliges Switzerland and the 28 EU member states to collect banking data from 2017 and exchange it from 2018. It will take over from the EU-Switzerland agreement on the taxation of savings in force since 2005. The exemption from withholding tax in this Agreement for cross-border payments of dividends, interest and royalties between related companies is transferred to the new Agreement. The withholding tax system applies to all interest payments made by a paying agent on Swiss territory to a nature established for tax purposes in an EU Member State. This is initially set at 15% and 35% by 2011. 75% of the revenue from this withholding tax system goes to the Member State concerned, the rest to the Federal State and the cantons („revenue sharing“). The agreement also provides that customers of foreign banks can choose between a withholding tax system and voluntary reporting to the tax authorities.

– under double taxation treaties with third countries, neither company is fiscally established in that third country and one of the important factors in the taxation of savings income is the abolition of the taxation of dividends, interest and royalties between related companies in the source State (e.g. .