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Audit Mutual agreement procedure management - State Secretariat for International Finance

Audit number: 17453

The State Secretariat for International Finance (SIF) is the responsible authority for negotiating mutual agreement procedures with partner states on the issues of double taxation of natural persons and legal entities. Mutual agreement procedures based on double taxation agreements are intended to avoid or eliminate taxation which is contrary to an agreement. A request must be initiated by the taxpayer. At present, pending proceedings amounting to around CHF 8 billion in tax base (assessment basis on which the tax is determined) remain open to negotiation. An analysis of completed procedures shows that around a quarter of this goes to the partner state. The number of mutual agreement procedures has been increasing for years due to fiscal and political activities in Switzerland and abroad.