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The Federal Council, together with Denmark, Luxembourg, Norway, France, Mexico and the United Kingdom, has given the approved authorities for the signature of the DTAs. The remaining initialled DTAs will shortly be submitted to the Federal Council for approval for signature. Since the Federal Council`s decision of 13 March 2009, France is, after Denmark and Luxembourg, the third country with which Switzerland has signed a DBA containing the extended mutual assistance clause provided for in Article 26 of the OECD Model Agreement. To be removed from the OECD Secretariat`s “grey list” for the G20, twelve agreements containing the OECD standard must be signed. The new double taxation agreement between Switzerland and France contains three important inheritance changes. Under the new tax treaty, beneficiaries of the estate of deceased persons who own real estate in Switzerland or France would be taxed in the country where the property is located if the deceased has resided in that country for more than 8 years. Heirs of real estate that inherits shares in companies that hold real estate are taxed in the country where they reside and the physical ownership of a national country, established in France, is taxed in France. No withholding tax is levied on royalties paid to foreign beneficiaries. Regardless of a double taxation agreement, profits transferred abroad by the Swiss establishment of a foreign company are not subject to withholding tax. Steps before entry into force Initialling is defined as the approval of a contractual text by initial annexes. Negotiators can thus provisionally prepare the negotiated text of the DTAs (and other international conventions). The initialled text is initially confidential.

A summary report informs the cantons and professional organisations concerned and invites them to submit their comments. Representatives of experts from the cantons can also take part in negotiations with countries that are important to Switzerland. The agreement will only be published after it has been signed. The Federal Council reserves the right to sign the agreement. The Federal Department of Finance (EFD) has been created. If the Agreement has been approved by the Partner State, it may enter into force. The date of entry into force depends on the agreement in question. The provisions of the DCM apply in accordance with the rules set out in the agreement, generally from 1 January of the calendar year following the date of entry into force.