The State Secretariat for International Financial Matters SIF announced on 13 April 2023 that the competent authorities of Switzerland and Germany have concluded a consultation agreement on the application of Article 15(4) of the double taxation agreement between Switzerland and Germany.
Article 15 (4) is now applied to all open cases until December 31, 2025, also to persons who are not and/or without function registered in the Swiss Commercial Register, but whose management and representation powers correspond at least to those of a Prokura.
The state-related information on Germany is available here; the above-mentioned mutual agreement here.
