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Rappresentante fiscale IVA in Svizzera
January 25, 2016
Switzerland and Germany: the agreement based on the Rubik model has been signed
August 10, 2011
The agreement between Switzerland and Germany based on the so called Rubik Model was signed today and should come into force at the beginning of 2013, after the approval by the respective governments and parliaments. The agreement provides that financial income and capital gains deriving from undeclared assets located in the Confederation and owned by German investors will be subject to an anonymous withholding tax at source of 26.375%. The amount of the rate is determined on the grounds of the 25% German tax and the solidarity surcharge in force in this country. The revenue so collected will then be forwarded to the German authorities, without, however, revealing the identity of the taxpayer. This system therefore replaces the exchange of information.
German capital kept for years in Swiss accounts is subject to an anonymous tax, the amount of which is established between 19% and 34%, depending on the number of years of deposits and the value thereof. It will be also possible for German taxpayers to declare income received to the tax authorities, without suffering from any criminal consequences.
The agreement also provided for a payment in advance of 2 billion Swiss francs by the Swiss banks on German funds deposited in the past. The amounts paid to the German authorities will be recovered in the future and charged on German customers.
In order to prevent a future unbalanced flow of investments towards Switzerland, the agreement allows German authorities to submit requests of information to Swiss authorities. Such requests should contain the name of the client, but that of the bank is not necessary. Requests of information will have to be based on plausible reasons and will be numerically limited (i.e. max 750 the first year, and 999 the second). Fishing expeditions, i.e. the general and indiscriminate research of information, are still not allowed.
A similar agreement between Switzerland and the United Kingdom is expected to be signed in the coming days.