Treaty detail
Switzerland - Germany tax treaty
A practical treaty page built around the official treaty text, key withholding categories, permanent-establishment rules, and article-level summaries.
Signed
1971-08-11
Effective
1972-12-29
Articles seeded
6
Withholding snapshot
Dividends
Individual rate: 15% · Corporate rate: 0%
The treaty as amended provides zero treatment for qualifying corporate shareholders with substantial direct ownership. The 15 percent rate applies to portfolio dividends.
Interest
Rate: 0%
The treaty generally results in zero source-country withholding on qualifying interest.
Royalties
Rate: 0%
The treaty generally eliminates source-country royalty withholding.
Permanent establishment
Construction threshold: more than 12 months
Dependent-agent analysis follows the treaty wording as amended by protocol.
Other treaty flags
Pension treatment is article-specific. The treaty includes detailed frontier-worker, pension, and government-service provisions.
Seeded article summaries
Article 4
Residence
Defines treaty residence under the 1971 wording as amended by protocols.
Article 4 has been refined by multiple protocols. Cross-border worker rules are particularly important given the German-Swiss border.
Article 5
Permanent Establishment
Sets the business-presence threshold with construction and frontier-worker provisions.
The treaty uses a 12-month construction-site threshold and includes specific provisions on cross-border workers and frontier-employment fact patterns.
Article 7
Business Profits
Generally reserves business profits to the residence state in the absence of a PE.
Article 7 has been refined by protocol.
Article 10
Dividends
Caps source-country dividend withholding with a zero rate for qualifying substantial shareholders.
Article 10 produces a zero rate for qualifying corporate shareholders with substantial direct ownership. Portfolio dividends face the 15 percent ceiling.
Article 11
Interest
Generally removes source-country withholding on qualifying interest.
Article 11 typically eliminates source-country withholding on qualifying interest.
Article 12
Royalties
Generally removes source-country withholding on qualifying royalties.
Article 12 eliminates source-country royalty withholding under the article as amended.
Official text
Other treaties involving these jurisdictions
Computed from the cross-reference graph. Links open the related entity on this site.
This entry cites
- TreatyUS–DE treaty
- TreatyUS–CH treaty
- TreatyGB–DE treaty
- TreatyGB–CH treaty
- TreatyCA–DE treaty
- TreatyDE–FR treaty
- TreatyDE–NL treaty
- TreatyDE–JP treaty
Primary sources
- BMF: DoppelbesteuerungsabkommenVerified 2026-05-20
- Swiss Federal Tax Administration treaty pageVerified 2026-05-20
Important disclaimer
This library is for general tax education only. Always verify filing obligations, due dates, and tax consequences against the cited primary source or with a qualified tax professional.