Switzerland and Russia
have signed a revised double taxation agreement (DTA) that
formalises the exchange of tax information and taxes on income and
capital.

The Swiss and Russian
governments agreed to introduce the zero rate for interest payments
and eliminate the residual tax on dividend payments to pension
funds and the central banks of both countries.

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However, so-called
‘fishing expeditions’, where authorities ask for access to a large
number of client accounts, will not be permissible under the
revised agreement.

The agreement is
significant since Switzerland has been one of the key offshore
markets for Russian HNW, although exact estimates on the amount of
Russian wealth kept in Switzerland are difficult to
obtain.

 

Changes to
information exchange

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Swiss and Russian
authorities will only be able to request an exchange of tax
information once the normal procedures to obtain the information
under domestic law have been exhausted.

When making a tax
information request under the agreement, the requesting state must
provide all the information below:

 

  • the identity of the person under
    examination or investigation;
  • the period of time for which the
    information is requested;
  • a statement of the information sought
    including the form in which the requesting state wishes to receive
    the information from the requested state;
  • the tax purpose for which the information
    is sought;
  • the name and address of any person
    believed to be in possession of the requested
    information.

 

Switzerland has signed
more than 30 such agreements and DTAs have been renegotiated since
it agreed to comply with the Organisation for Economic Co-operation
and Development (OECD) standard on tax information exchange in
2009.