Agreement between Switzerland and the European Union on the taxation of savings - a balanced "compromis Helvétique"

The bilateral agreement on the taxation of savings (Savings Agreement) between Switzerland and the European Union, signed in October 2004, is important for both parties. For the European Union, it represents the implementation of "equivalent measures" to those in the EC Directive on the taxation of savings income in the form of interest payments. For Switzerland, it is the result of a balanced compromise between the introduction of unilateral measures to secure the taxation of interest within the European Union, while preserving bank secrecy. After summarizing the main features of the Savings Agreement, this article analyses its three essential elements: the retention on interest payments, the exchange of information in the case of "tax fraud and the like", and the introduction of rules comparable to those in the EC Parent-Subsidiary and Interest and Royalties Directives.