Turner Little looks at a double taxation agreement (DTA) entered into in July 2015 between Switzerland and Liechtenstein is scheduled to start in 2017. This replaces the existing DTA which was created in 1995 and supposedly creates “legal certainty” particularly concerning cross-border tax planning for companies and asset structures.
Objectives
The aim of the DTA is to avoid double taxation by:
- Exempting taxable income
- Giving credit for taxes paid; and
- Reducing withholding taxes
Characteristics of the new Double Taxation Agreement
The DTA is OECD compliant and although the exchange of tax related information is available on request, the DTA does not form a legal basis for the automatic exchange of information (AEoI). The AEoI regime between Switzerland and Liechtenstein will require a separate intergovernmental agreement. Although Group requests are possible, “fishing expeditions” for information are not permitted.
The DTA covers, natural persons, legal entities and Liechtenstein asset structures, including foundations, registered trust companies, charities and pension schemes.
Turner Little
Turner Little can assist with these or similar structures in other locations affording the same benefits and examples of Asset structuring options for both natural persons and legal entities can be obtained from Turner Little. For a full range of services provided see www.turnerlittle.com.
