Statistics from January to July 2010 show that imports from Switzerland amounted to 72 million euros (mainly pharmaceuticals, 91.2 million euros in the same period in 2009, while Malta`s exports increased to 9.3 million euros (mainly machinery and pharmaceuticals) compared to 5.7 million euros in the first half of 2009. The agreement will enter into force after ratification by both countries. In the case of wealthy individuals living abroad, a DBA could make some countries more advantageous to stay there. If the second country had entered into a double taxation agreement with the United Kingdom, the tax would only be levied on income from British operations. The remaining revenue would be protected from UK tax. Individuals with dual residences in the UK and another country who have a DBA agreement can apply for full or partial tax relief for income. These include bank interest, royalties, most working pensions and pensions. Governments have recognized that this would be unfair and discourage international trade/business. As a result, they each put in place their own rules to prevent the same income from being taxed twice. In some cases, the amount of tax paid in one country can be deducted from what is due in another country. These agreements or contracts are called Double Tax Agreements (DBA) and should be integrated into your tax planning system.

This section describes the application of double taxation agreements (DTCs) in the case of international recruitment of workers by non-resident companies (staff rental companies). Income taxation can be a problem for international workers and individuals who may reside in more than one country. In countries where global taxation is applied, a non-resident national working abroad could be taxed on his or her income in his or her country of origin and in the country where he or she is earned. In some cases, it is possible for the person to apply for tax relief, but the amount of relief depends on the DBA agreement between the UK and the country from which your income comes. The situation becomes more complicated when tax rates vary from country to country. So what`s going on? To further understand the double taxation convention, we gave a typical example: royalties paid to foreign beneficiaries are not subject to withholding tax. Profits repatriated abroad by the Swiss establishment of a foreign company do not attract withholding tax, regardless of a double taxation agreement. Switzerland has double taxation agreements with more than 80 other countries, more than 30 of which are based on the OECD model. The general effect of contracts for non-residents of the contracting states is that they can benefit from a partial or total refund of the tax withheld by the Swiss paying body.

Although the total amount of the withholding tax is deducted at source, the difference can be recovered from the Swiss tax authorities from the non-resident. If there is no double taxation agreement that deducts withholding tax deducted in foreign jurisdiction on transfers made to a Swiss company, a tax credit is entered into in Switzerland. Some of the countries that have double taxation agreements with Switzerland are included below: the protocol has become necessary to soften the European Commission, which had considered that the agreement could be contrary to the European Treaty. By threatening to refer the matter to the European Court of Justice, the United Kingdom and Switzerland have agreed that account holders who have already paid the 35% withholding tax due under the European Savings Tax will be subject to a final withholding tax of 13% in order to reduce the tax debt on interest payments. In October 2010, an agreement was signed to begin negotiations for an agreement to tax unreported British accounts in Switzerland and other information regarding tax and banking information shared between the two states.