On 13 December 2019, the Swiss Federal Council launched a consultation on the Federal Act on the Implementation of International Tax Agreements (ITAIA). The Federal Council plans to adapt the existing law to the recent changes in international tax law. The total revision of the Federal Act of 22 June 1951 on the Implementation of International Federal Conventions on the Avoidance of Double Taxation (new version: ITAIA) is intended to ensure that tax agreements, particularly double taxation agreements, can continue to be applied easily and with legal certainty in the future. The revision of the law stipulates how mutual agreement procedures are to be carried out at national level. The defined procedure largely follows current practice and is applied only if the agreement does not contain any deviating provisions. The revision also provides for certain simplifications. Moreover, it contains the key points for withholding tax relief based on international agreements, as well as criminal provisions in connection with relief from withholding taxes on capital income. The consultation runs until 27 March 2020.
December 16 2019