(a) with respect to the amendments to Article 24 (mutual agreement procedure) of the Convention by Article IX of the Amendment Protocol from the date of the amendment protocol`s entry into force, In view of the tax period to which the issue relates, the Federal Council announced on 13 March 2009 that Switzerland intended to adopt OECD standards for tax assistance, in accordance with Article 26 of the OECD Model Convention on Taxation. The decision allows the exchange of information with other countries in individual cases where a concrete and reasoned request has been made. The Federal Council has decided to withdraw the reserve for the OECD`s model tax treaty and to begin negotiations on the revision of double taxation conventions. However, Swiss banking secrecy remains intact. S.I. 1978/1408; the provisions of this decision were amended by the agreements in flight plans S.I. 1982/714, 1994/3215, 2007/3465 and 2010/2689 and were supplemented by the agreement on the S.I. 2012/3079 list. 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. The agreement will strengthen, among other things, cross-border tax cooperation and improve banks` access to the market.
Negotiations began in early 2011 and the agreement was signed on 6 October 2011. On March 20, 2012, a protocol was signed to clarify outstanding issues. The OECD`s Multilateral Convention on the Implementation of Measures to Prevent Erosion and Profit Transfer („Multilateral Instrument“ or „MLI“) of the OECD came into force in the United Kingdom on 1 October 2018 and will have a fundamental influence on how taxpayers have access to the double taxation (DT) conventions to which they apply. It began from 1 January 2019 (z.B with regard to WHT) for the UK DT, with the territories also ratified before 1 October 2018, in which these are tax treaties. The specific dates on which the MLI takes effect for other purposes or for other TDAs depend on when other contracting parties submit their ratification instruments to the OECD and the options and reservations they have submitted.