In its communication of 27 June 2022, the State Secretariat for International Financial Matters (SIF) points out the legal validity of the following mutual agreements on the taxation of cross-border gainful activity in the context of the pandemic:
- Germany: The Mutual Agreement applies if employers and states take measures to combat the spread of COVID-19 and remains in force until 30 June 2022;
- Austria: no mutual agreement;
- France: The Memorandum of Understanding applies when there are measures taken by States in connection with combating the proliferation of COVID-19 and remains in force until 30 June 2022, unless it is extended; the competent authorities are currently holding talks on the bilateral formalisation of a possible new Memorandum of Understanding from 1 July 2022 (cf. our article of 2 July 2022, according to which the competent authorities of Switzerland and France have in the meantime agreed in a joint declaration to extend the Memorandum of Understanding until 31 October 2022);
- Liechtenstein: The Memorandum of Understanding applies when there are measures taken by employers and states in connection with combating the spread of COVID-19. It expired on 31 March 2022;
- Italy: The Memorandum of Understanding applies when there are measures taken by States in relation to combating the proliferation of COVID-19 and according to the conditions of this Memorandum; a tacit extension is foreseen. Therefore, the end of its application is not known at this stage.
The communication is available here.
