Standard Contracts
since 1929Tax Planning Agreement • October 22nd, 2009
Switzerland and Liechtenstein have tra- ditionally maintained close, neighbourly economic relations. The same cannot be said, however, in reference to tax matters. A “rump agreement” that primarily regu- lates taxation of cross-border commuters and other tax issues has been in place between the two countries since 1995, but this agreement does not cover Swiss with- holding tax or Liechtenstein’s coupon tax (which although abolished as of 1 January 2011 still applies to the distribution of earnings and reserves that already existed prior to that time). When, for example, a Swiss company, be it a public limited com- pany (AG) or a private limited company (GmbH), pays a dividend to a shareholder with a registered office or place of resi- dence in Liechtenstein, swiss withholding tax in the amount of 35% is levied and remitted to the Swiss Federal Tax Admin- istration, which means the shareholder receives 65% of the actual payout. There are, however, no provisions for obtaining a refund of
