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Commentary

6.2 Double tax relief

Switzerland

Where no double tax agreements apply, double taxation on foreign source income is in principle alleviated by means of the deduction method (foreign tax deducted from the taxable income).

Where a double tax agreement exists, double taxation is in principle eliminated in accordance with the exemption method. The list of double tax agreements signed by the Switzerland can be found online.

However, the credit method is used for dividends, interest and, sometimes, royalties derived by Swiss residents from another contracting country. Under the credit method, the foreign tax at source is credited against Swiss taxes, however, the credit may not be higher than the amount of Swiss taxes on such income. A so-called lump tax credit mechanism has been enacted for this purpose.

Switzerland has a broad network of income (and wealth) tax treaties.

Switzerland generally applies the 'exemption with progression' method for qualified foreign sourced income and not a tax credit method. However, when investment income derives from a country with which Switzerland has concluded a tax treaty, a tax credit is available for the non-refundable part of withholding

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