How to prove tax residency for DTA application?

Obtain a Swiss Certificate of Residence (COR) from the competent tax authority. Submit proof of domicile, ID, and tax return. Processing: ~2–4 weeks. Present the COR to the foreign authority/withholding agent to claim treaty benefits.

What if there is no DTA with my second citizenship country?

Switzerland grants unilateral relief via the ordinary credit method: foreign tax paid can be credited up to the Swiss tax on that income. No refund for excess foreign tax. Documentation of foreign tax is required; withholding at source isn’t reduced.

Are pensions subject to double taxation?

Under many Swiss DTAs, private pensions are taxable only in the state of residence. Exceptions: government pensions and some social security benefits. Check the specific DTA; if tax is withheld contrary to treaty, file a refund with a Swiss COR.

Where to get advice for my specific case?

Consult a Swiss tax advisor or international tax attorney. Companies should engage specialists for transfer pricing and PE risk. For disputes, contact the Swiss SIF (International Tax Division) promptly to meet MAP deadlines.

How long does it take to resolve a MAP case?

Typically 12–24 months, depending on complexity and the foreign authority’s responsiveness. OECD data (2023) shows Switzerland resolved 87% within 24 months.

Can I claim treaty benefits if I hold dual citizenship?

Yes, but eligibility depends on tax residency, not citizenship. If both countries claim residency, apply the treaty tie-breaker (home, vital interests, habitual abode, citizenship). Once treaty residence is set, claim benefits accordingly.

17.12.2025

Double tax treaties in Switzerland: complete list and guide

Switzerland maintains one of the world's most comprehensive networks of double taxation agreements (DTAs), with over 100 bilateral treaties designed to prevent the same income from being taxed twice across jurisdictions.

Taxes in Switzerland

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