The Federal Tax Administration (FTA) has published Circular No. 212 "Information sheets for withholding tax and overviews of double taxation agreements" (as at 1.1.2025).
An amendment to the double taxation agreement with Kuwait that came into force on January 1, 2025 will lead to changes with regard to private-law pension benefits and substitute income. Pensions are now also subject to withholding tax. A refund of withholding tax is only possible for both pensions and 2nd pillar lump-sum benefits from private pension plans if proof of taxation from Kuwait is submitted.
The information sheet "Withholding tax on substitute income" has also been amended. The information on the cross-border commuter agreement of 23 December 2020 with Italy has been clarified in sections 2.3.3, 3.2 and 4.2.
The FTA has supplemented its information sheets and overviews accordingly.
Circular no. 212 is available here.
