On June 14, 2024, the Federal Council adopted the dispatch on the amendment of the DTA with Germany.
The protocol of amendment does not provide for any significant changes to the allocation of taxing rights between Switzerland and Germany with regard to Swiss practice. However, it does contain various clarifications in connection with dependent cross-border employment and new provisions on the mutual agreement procedure.
In addition, the protocol adopts the approach of the Organization for Economic Cooperation and Development (OECD) for the allocation of corporate profits to permanent establishments and implements the minimum standards from the BEPS project in terms of DTAs.
The full press release with further information is available here .
