On 21 March 2025, the Swiss parliament gave final approval to the pending protocol to the 1971 income and capital tax treaty with Germany. The protocol, signed 21 August 2023, is the sixth to amend the treaty and includes the following main changes:
- The preamble is replaced in line with OECD BEPS standards;
- The agent PE provisions of Article 5 (Permanent Establishment) are updated, providing that where a person — other than an agent of an independent status to whom paragraph 5 applies — is a…